draft environmental impact statement renewal of the … 4.… · · 2017-08-18draft environmental...

BLM/AK/PT-02/026+2880+990

Draft Environmental Impact Statement

Renewal of the Federal Grant for the Trans-AlaskaPipeline System Right-of-Way

Volume 4: Appendixes A through F

U.S. Department of the InteriorBureau of Land Management

July 2002

iii

DOCUMENT CONTENTS

VOLUME 1

Executive SummaryChapter 1: IntroductionChapter 2: AlternativesChapter 3: Affected Environment

VOLUME 2

Section 4.1: Existing Mitigation MeasuresSection 4.2: Impacting FactorsSection 4.3: Proposed Action Alternative Analysis − Routine OperationsSection 4.4: Spills Analysis for Proposed ActionSection 4.5: Less-Than-30-Year Renewal Alternative AnalysisSection 4.6: No-Action Alternative Analysis

VOLUME 3

Section 4.7: Cumulative EffectsSection 4.8: Other NEPA ConsiderationsSection 4.9: References for Chapter 4Chapter 5: Consultation and CoordinationChapter 6: Review and Analysis of Comments Received on the Draft

Environmental Impact Statement (Reserved for Final EIS)Chapter 7: List of PreparersChapter 8: GlossaryChapter 9: Glossary of Laws, Executive Orders, and Regulations Cited

in This DEIS

VOLUME 4

Appendix A: Methodology DescriptionsAppendix B: TAPS ROW Map AtlasAppendix C: Hazardous Materials and Waste ManagementAppendix D: Subsistence in the Vicinity of the TAPSAppendix E: ANILCA Section 810 Analysis of Subsistence ImpactsAppendix F: Federal Agreement and Grant of Right-of-Way for the

Trans-Alaska Pipeline

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VOLUME 4 CONTENTS

APPENDIX A: Methodology Descriptions ..................................................................................... A-1

APPENDIX B: TAPS ROW Map Atlas............................................................................................ B-1

APPENDIX C: Hazardous Materials and Waste Management ..................................................... C-1

APPENDIX D: Subsistence in the Vicinity of the TAPS ................................................................ D-1

APPENDIX E: ANILCA Section 810 Analysis of Subsistence Impacts ......................................... E-1

APPENDIX F: Agreement and Grant of Right-of-Way for Trans-Alaska Pipeline......................... F-1

VOLUME 4 FIGURES

A-1 North Slope Crude Oil Production from 1988 to 2000 ....................................................... A-38

A-2 Projections of North Slope Crude Oil Production............................................................... A-38

A-3 Spill Frequency by TAPS Segment.................................................................................... A-40

A-4 Number of Spills by Size over TAPS Lifetime.................................................................... A-40

D-1 Example of the Seasonality of the Subsistence Harvest in Copper River Basin ............... D-6

D-2 Changing Harvests over Time for Selected Resources in Stevens Village ....................... D-7

D-3 Communities Considered in the TAPS ROW Renewal EIS............................................... D-9

D-4 Geographic Extent of Exxon Valdez Oil Spill..................................................................... D-11

D-5 Subsistence Harvest Areas Associated with Alatna .......................................................... D-17

D-6 Subsistence Harvest Areas Associated with Anaktuvuk Pass........................................... D-23

D-7 Subsistence Harvest Areas Associated with Chenega Bay............................................... D-29

D-8 Subsistence Harvest Areas Associated with Chitina ......................................................... D-33

D-9 Subsistence Harvest Areas Associated with Copper Center............................................. D-37

D-10 Subsistence Harvest Areas Associated with Evansville .................................................... D-47

D-11 Subsistence Harvest Areas Associated with Gakona........................................................ D-51

D-12 Subsistence Harvest Areas Associated with Glennallen ................................................... D-57

D-13 Subsistence Harvest Areas Associated with Gulkana....................................................... D-63

D-14 Subsistence Harvest Areas Associated with Hughes ........................................................ D-67

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VOLUME 4 FIGURES (Cont.)

D-15 Subsistence Harvest Areas Associated with Kenny Lake ................................................. D-71

D-16 Subsistence Harvest Areas Associated with Manley Hot Springs..................................... D-75

D-17 Subsistence Harvest Areas Associated with Minto............................................................ D-79

D-18 Subsistence Harvest Areas Associated with Nanwalek..................................................... D-85

D-19 Subsistence Harvest Areas Associated with Nuiqsut ........................................................ D-91

D-20 Subsistence Harvest Areas Associated with Paxson ........................................................ D-97

D-21 Subsistence Harvest Areas Associated with Rampart....................................................... D-105

D-22 Subsistence Harvest Areas Associated with Stevens Village ........................................... D-111

D-23 Subsistence Harvest Areas Associated with Tanana ........................................................ D-117

D-24 Subsistence Harvest Areas Associated with Tatitlek......................................................... D-123

D-25 Subsistence Harvest Areas Associated with Tonsina........................................................ D-131

VOLUME 4 TABLES

A-1 Conceptual Model for the Effects of the Proposed Action, the Less-Than-30-YearRenewal Alternative, and No Action on Biological Resources ......................................... A-17

A-2 Economic and Demographic Impact Parameters Examined for the Proposed Action,Less-Than-30-Year Renewal Alternative, and No-Action Alternative................................ A-21

A-3 Types and Properties of Oil ............................................................................................... A-35

A-4 Event Frequency Classifications ....................................................................................... A-36

A-5 Physical Constants for Ice-Melt Calculation ...................................................................... A-44

A-6 Past, Present, and Reasonably Forseeable Future Actions .............................................. A-50

C-1 Summary of EPCRA Tier II Report for Calendar Year 2000 .............................................. C-6

C-2 Hazardous Wastes Generated at the Mainline Refrigeration Unit 2, NorthstarTerminal, and VALDEZ Marine Terminal in 1998−1999 .................................................... C-11

C-3 Solid Waste Disposal Sites Currently Used by APSC ....................................................... C-17

C-4 APSC Recycled Waste Types, Sources, Disposition, and Amounts ................................. C-19

C-5 Ballast Water Treatment Facility Influent Sources at Valdez Marine Terminal.................. C-21

C-6 Ballast Water Treatment Facility Effluent Flow Averages in 2000..................................... C-26

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V0LUME 4 TABLES (Cont.)

C-7 Discharges Addressed in the Linewide NPDES Permit for 1998....................................... C-27

C-8 Sanitary Waste Treatment Plant Effluent Flow Averages for 2000.................................... C-28

C-9 Typical Effluent Flows of Sanitary Wastewater at Various Sites in 1997........................... C-30

C-10 Amounts of Medical Wastes and Solid Wastes Burnedin APSC Incinerators in 2000............................................................................................. C-33

C-11 Contaminated Soil Stockpiled at the Valdez Marine Terminal........................................... C-37

C-12 North Slope Injection Wells................................................................................................ C-40

D-1 Communities in Proximity to the TAPS, Demographic and Subsistence Overview........... D-13

D-2 Subsistence Harvest Summary for Alatna in 1998 ............................................................ D-16

D-3 Subsistence Harvest Summary for Allakaket/Alatna in 1982............................................. D-19

D-4 Subsistence Harvest Summary for Allakaket in 1998........................................................ D-20

D-5 Subsistence Harvest Summary for Anaktuvuk Pass in 1993............................................. D-21

D-6 Subsistence Harvest Summary for Chenega Bay in 1993................................................. D-26

D-7 Subsistence Harvest Summary for Chitina in 1987 ........................................................... D-32

D-8 Subsistence Harvest Summary for Copper Center in 1987 ............................................... D-36

D-9 Subsistence Harvest Summary for Cordova in 1997......................................................... D-40

D-10 Subsistence Harvest Summary for Evansville in 1998 ...................................................... D-43

D-11 Subsistence Harvest Summary for Bettles/Evansville in 1982 .......................................... D-44

D-12 Subsistence Harvest Summary for Gakona in 1987.......................................................... D-50

D-13 Subsistence Harvest Summary, Glennallen in 1987 ......................................................... D-54

D-14 Subsistence Harvest Summary for Gulkana in 1987 ......................................................... D-60

D-15 Subsistence Harvest Summary for Hughes in 1982 .......................................................... D-66

D-16 Subsistence Harvest Summary for Kenny Lake in 1987.................................................... D-70

D-17 Subsistence Resources Harvested by Residents in the Manley Hot Springsand Eureka Area in 1996 ................................................................................................... D-73

D-18 Subsistence Harvest Summary for Minto in 1984.............................................................. D-78

D-19 Subsistence Harvest Summary for Nanwalek in 1997....................................................... D-82

D-20 Subsistence Harvest Summary for Nuiqsut in 1993a ........................................................ D-88

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VOLUME 4 TABLES (Cont.)

D-21 Subsistence Harvest Summary for Paxson in 1987........................................................... D-94

D-22 Subsistence Harvest Summary for Port Graham in 1997 .................................................. D-100

D-23 Subsistence Harvest Summary for Rampart in 1993......................................................... D-103

D-24 Subsistence Harvest Summary for Stevens Village in 1984.............................................. D-108

D-25 Subsistence Harvest Summary for Tanana in 1987 .......................................................... D-114

D-26 Subsistence Harvest Summary for Tatitlek in 1997........................................................... D-120

D-27 Subsistence Harvest Summary for Tazlina in 1987........................................................... D-126

D-28 Subsistence Harvest Summary for Tonsina in 1987.......................................................... D-129

D-29 Subsistence Harvest Summary for Wiseman in 1991........................................................ D-134

ix

Notation

The following is a list of acronyms and abbreviations (including units of measure) used in this document.Certain abbreviations used only in tables, equations, and as reference callouts are not included here butare defined in the respective tables, equations, and reference lists.

Acronyms and Abbreviations

AAAQS Alaska Ambient Air Quality StandardsAAC Alaska Administrative CodeAADT annual average daily trafficACEC areas of critical environmental concernACM asbestos-containing materialsACMA Alaska Coastal Management ActACMP Alaska Coastal Management ProgramACS Alaska Clean SeasADEC Alaska Department of Environmental ConservationADF&G Alaska Department of Fish and GameADGC Alaska Department of Government CoordinationADNR Alaska Department of Natural ResourcesADT average daily trafficAFB Air Force BaseAFFF aqueous film-forming foamAFN Alaska Federation of NativesAK AlaskaAKOSH Alaska Occupational Safety and HealthALOHA Areal Locations of Hazardous AtmospheresAMHS Alaska Marine Highway SystemAMM asset maintenance managementANCSA Alaska Native Claims Settlement ActANILCA Alaska National Interest Lands Conservation ActANSI American National Standards InstituteANUA Alaska Native Utilization AgreementANWR Arctic National Wildlife RefugeAO Authorized Officer (Joint Pipeline Office)AOGCC Alaska Oil and Gas Conservation CommissionAPHIS Animal and Plant Health Inspection ServiceAPI American Petroleum InstituteAPSC Alyeska Pipeline Service CompanyAQCR Air Quality Control RegionAQRV air-quality-related valueARCO Atlantic Richfield CompanyARRC Alaska Railroad CorporationARRT Alaska Regional Response TeamAS Alaska StatuteASME American Society of Mechanical EngineersATV all-terrain vehicle

BE biological evaluationBLM Bureau of Land Management (U.S. Department of the Interior)BLS Bureau of Labor StatisticsBMP best management practiceBOD biochemical oxygen demand

x

BOD5 biochemical oxygen demand measured over a five-day periodBP British PetroleumBPXA British Petroleum Exploration (Alaska), Inc.BS&W basic sediments and waterBTEX benzene, toluene, ethylbenzene, xyleneBTT biological treatment tankBWT ballast water treatmentBWTF Ballast Water Treatment FacilityBWTS ballast water treatment system

CBR Constitutional Budget ReserveCBRF Constitutional Budget Reserve FundCCP Central Processing PlantCDMS Corrosion Data Management SystemCEO chief executive officerCEQ Council on Environmental QualityCFC chlorofluorocarbonCFR Code of Federal RegulationsCMP coastal management programCNG compressed natural gasCO carbon monoxideCO2 carbon dioxideCP Contingency PlanCPF Central Production FacilityCS containment siteCSU conservation system unitCY calendar yearCZ coastal zoneCZM coastal zone managementCZMA Coastal Zone Management Act

DAF dissolved air flotationDBGC designated big-game crossingDCE design contingency earthquakeDDT dichloro-diphenyl-trichloro-ethaneDEIS draft environmental impact statementDHCMA Dalton Highway Corridor Management AreaDOE U.S. Department of EnergyDOI U.S. Department of the InteriorDOT Department of TransportationDOT/OPS Department of Transportation, Office of Pipeline SafetyDRA drag reducing agentDRO diesel-range organicsDS drill siteDSMA digital strong-motion accelerograph

EIA Energy Information AdministrationEFH essential fish habitate.g. exempli gratia (for example)EGHP exhaust-gas horsepowerEIA Energy Information AdministrationEIS environmental impact statementEMS environmental monitoring systemEPA U.S. Environmental Protection AgencyEPCRA Emergency Planning and Community Right-to-Know ActER environmental reportERPG emergency response planning guidelineERV Escort Response Vessel

xi

ESA Endangered Species Actet al. and others

FAA Federal Aviation AdministrationFACA Federal Advisory Committee ActFDA U.S. Food and Drug AdministrationFDS Fire Dynamics Simulation (computer model)Fe ironFe2O3 ferric oxideFEIS final environmental impact statementFR Federal RegisterFSIH Fire Safety and Industrial HygieneFTE full-time equivalent

GAO General Accounting OfficeGC Gathering CenterGHG greenhouse gasGIS geographic information systemGMU Game Management UnitGNOME General NOAA Oil Modeling EnvironmentGRO gasoline-range organicsGSP gross state product

H2O2 hydrogen peroxideH2S hydrogen sulfideHAP hazardous air pollutantHAZCORE Hazardous Materials Consolidation and RedistributionHAZMAT hazardous materialHC hydrocarbonHCFC hydrochlorofluorocarbonHCl hydrogen chlorideHg mercuryHRR heat release rateHVAC heating, ventilation, and air conditioning

i.e. that is (id est)IMPROVE Interagency Monitoring of Protected Visual EnvironmentsIRIS Integrated Risk Information SystemIRT Initial Response TeamISC3 Industrial Source Complex Model (Version 3)ISCST Industrial Source Complex Short TermIWSS industrial wastewater sewer system

JPO Joint Pipeline Office

Ldn day-night average sound levelLeq equivalent steady sound levelLEFM leading-edge flow meterLNG liquefied natural gasLVB line volume balance

MAP Man in the Arctic ProgramMCCF mobile contingency camp facilityMCL maximum contaminant levelMEI maximally exposed individualMEK methyl ethyl ketoneMGV manual gate valveMLA Mineral Leasing Act

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MLR Mainline RefrigerationMMC Marine Mammal CommissionMMPA Marine Mammal Protection ActMMS Minerals Management ServiceMOA memorandum of agreementMP milepostMSDS Material Safety Data SheetsMSFCMA Magnuson-Stevens Fisheries Conservation and Management ActMSGP Multi-Sector General (NPDES) PermitMSWLF municipal solid waste landfill

N nitrogenNAAQS National Ambient Air Quality StandardsNADP National Atmospheric Deposition ProgramNAICS North American Industry Classification SystemNANA Northwest Alaska Native AssociationNEPA National Environmental Policy ActNF National ForestNFRAP no further remedial action plannedNGL natural gas liquidNH3 ammoniaNHPA National Historic Preservation ActNMDS National Missile Defense SystemNMFS National Marine Fisheries Serviceno. numberNOx nitrogen oxidesNO2 nitrogen dioxideNO3- nitrateNOAA National Oceanic and Atmospheric AdministrationNOD Notice of DisposalNOI Notice of IntentNORM naturally occurring radioactive materialNP national parkNPDES National Pollutant Discharge Elimination SystemNPP national park and preserveNPR National Petroleum ReserveNPR-A National Petroleum Reserve-AlaskaNPS National Park ServiceNRA national recreation areaNRHP National Register of Historic PlacesNS North SlopeNSB North Slope BoroughNSC National Safety CouncilNSPTS North Slope Production and Transportation SystemNWR national wildlife refugeNWS National Weather Service

O3 ozoneO&M operation and maintenanceOCC Operations Control CenterOCS Outer Continental ShelfODC ozone-depleting chemicalODP ozone-depleting potentialODS ozone-depleting substanceOMB Office of Management and BudgetOMS operational material siteOPA Oil Pollution ActOPS Office of Pipeline Safety (U.S. Department of Transportation)

xiii

ORC oxygen-releasing compoundORV off-road vehicleOSHA Occupational Safety and Health AdministrationOSHTF (Alaska) Oil Spill Health Task ForceOSPPR Oil Spill Prevention, Preparedness, and ResponseOSV oil spill volume

P phosphorusPA Programmatic AgreementPAH polycyclic aromatic hydrocarbonPAI Phillips Alaska, Inc.Pb leadPBT persistent, bioaccumulative, and toxicPCB polychlorinated biphenylPDF pipeline design floodPELs permissible exposure limitsPF Permanent FundPG Pasquill-GiffordpH hydrogen ion concentrationP.L. Public LawPM particulate matterPM2.5 particulate matter with a diameter less than or equal to 2.5 micrometersPM10 particulate matter with a diameter less than or equal to 10 micrometersPMP probable maximum precipitationPO4

3- phosphatePOP persistent organic pollutantPOTW publicly owned treatment worksPPE personal protective equipmentPPV peak particle velocityPRT prevention and response tugPS pump stationPSD Prevention of Significant DeteriorationPWS Prince William Sound

QA quality assurance

RCM reliability-centered maintenanceRCRA Resource Conservation and Recovery ActREAA Regional Educational Attendance AreaRGV remote gate valveRMP Resource Management PlanROD Record of DecisionROS recreation opportunity spectrumROW right-of-wayRRO residual-range organicsRSC reduced sulfur compounds

SARA Superfund Amendments and Reauthorization ActSCADA supervisory control and data acquisitionSD standard deviationSDWA Safe Drinking Water ActSERVS Ship Escort/Response Vessel SystemSHPO State Historic Preservation OfficerSi siliconSIC Standard Industrial ClassificationSIP state implementation planSO2 sulfur dioxideSOx sulfur oxides

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SPC State Pipeline Coordinatorspp. speciesSRS state recreation siteStat. statuteSWDS solid waste disposal siteSWPPP Storm Water Pollution Prevention PlanSWTP sanitary waste treatment plant

TAPAA Trans-Alaska Pipeline Authorization ActTAPS Trans-Alaska Pipeline SystemTAGS Trans-Alaska Gas SystemTCA 1,1,1-trichloroethaneTCP traditional cultural propertyTEEL temporary emergency exposure limitTEF toxic equivalency factorTLV threshold limit valueTPQs Threshold Planning QuantitiesTRI Toxics Release InventoryTSDF treatment storage and disposal facilityTSP total suspended particulatesTSS total suspended solidsTVB transient volume balanceTVR tanker vapor recovery

UAA University of Alaska-AnchorageUIC underground injection controlUSACE U.S. Army Corps of EngineersUSC United States CodeUSCG United States Coast GuardUSDA U.S. Department of AgricultureUSFS United States Forest ServiceUSFWS United States Fish and Wildlife ServiceUSGS United States Geological SurveyUV ultra-violet

VAHS Valdez Air Health StudyVHF very high frequencyVHS viral hemorrhagic septicemiaVMT Valdez Marine TerminalVOC volatile organic compoundVRM visual resource managementVSM vertical support memberVTS Vessel Traffic Service

WSR Wild and Scenic River

ZRAs Zone of Restricted Activities

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Units of Measure

acre-ft acre-foot (feet)bbl barrel(s)Btu British thermal unit(s)°C degrees centigradecm centimeter(s)cm3 cubic centimeterscSt centistoke(s)d daydB decibel(s)dBA A-weighted decibel(s)°F degrees Fahrenheitft foot (feet)ft2 square foot (feet)ft3 cubic foot (feet)g gravitational accelerationgal gallon(s)GW gigawatt(s)h hour(s)ha hectare(s)hp horsepowerin. inch(es)in.2 square inch(es)j joule(s)K kelvin degree(s)kg kilogram(s)km kilometer(s)km2 square kilometer(s)knot nautical mile(s) per hourkW kilowatt(s)L liter(s)lb pound(s)m meter(s)m2 square meter(s)

m3 cubic meter(s)mg milligram(s)mi mile(s)mi2 square mile(s)min minute(s)mL milliliter(s)mm millimeter(s)mmole millimole(s)mph mile(s) per hourMW megawatt(s)MYA million years agong nanogram(s)pCi picocurie(s)ppb part(s) per billionppm part(s) per millionpsi pound(s) per square inchpsig pound(s) per square inch gaugerpm revolution(s) per minutes second(s)scf standard cubic foot (feet)scfm standard cubic foot (feet) per minutewk week(s)YA years agoyd yard(s)yd3 cubic yardsyr year(s)µg microgram(s)µg-atoms microgram-atomsµm micrometer(s)µmole micromole(s)µR microroentgen(s)$/bbl dollar per barrel

A-1

Appendix A:

Methodology Descriptions

APPENDIX A A-2

A-3

Appendix A:Methodology Descriptions

A.1 Introduction

This appendix describes the methodologiesused to analyze the environmentalconsequences of implementing any of thealternatives presented in the draft environmentalimpact statement (DEIS). The alternatives are torenew the Federal Grant of right-of-way (ROW)for the Trans-Alaska Pipeline System (TAPS) fora period of 30 years (proposed action), to renewthe Federal Grant for a period of less than 30years, or to not renew the Federal Grant (noaction).

The methodologies used in the assessmentof the proposed action and alternatives arepresented by impact area (Sections A.2-A.15) inthe order that they are discussed in the mainbody of this DEIS. The method used for thecumulative analysis is presented separately inSection A.16. Major assumptions specific toindividual methodologies are discussed underindividual impact areas; however, severalassumptions apply for all methodologies and arepresented below:

• Current (2001) conditions of the TAPSdefine the base case for the analyses.

• Monitoring, maintenance, and repair of theTAPS would continue for the proposedaction.

• The TAPS would operate in compliance withall applicable regulations for the proposedaction.

• Operations at the Valdez Marine Terminalare treated as part of the proposed action.

• The North Slope and Prince William Soundactivities are analyzed separately in theDEIS as part of the cumulative impacts (seeSection A.16).

• Levels of activities that correspond to crudeoil throughput of 2.1 million barrels per day(bbl/d) (design capacity), 1.1 million bbl/d(base case), and 0.3 million bbl/d

(economically feasible minimum) areassumed to provide a range of reasonableoperational scenarios for assessing theimpact of the proposed action.

• The no-action alternative addresses removalof all aboveground components of the TAPS;belowground components would be cleanedand capped. One exception would be theremoval of belowground components at rivertraining structures.

• No new facilities would be constructed fordismantling and removing the TAPS (currentpump stations, workpads, and staging areaswould be used).

• Under the no-action alternative, gravel padsand disturbed surface soils would be left inplace and revegetated according toaccepted restoration practices.

• The impacts of such restoration activities arediscussed under no action.

A.2 Physical Environment:Geology, Seismicity,Soils, Permafrost,and HydrologicalResources

From an environmental perspective, renewalof the TAPS ROW Federal Grant could producedirect, indirect, and cumulative impacts on thephysical environment. Similarly, the environmentcould impact the TAPS.

Normal operations, routine maintenance,system upgrades, and accidents over the next30 years are impacting factors for the physicalenvironment under the proposed action. Underthe no-action alternative, impacting factors of theTAPS on the environment include dismantlingthe pipeline system, removing the dismantled

APPENDIX A A-4

system, accidents, and restoration activities. Theimpacting factors under the proposed action,less-than-30-year renewal alternative, andno-action alternative could:

• Modify rivers and streams by erosion,deposition, migration, and flow restriction;

• Create ponding and flooding along theROW;

• Drain and create thaw lakes;

• Degrade surface water and groundwaterquality;

• Deplete surface water and groundwaterresources;

• Spread contamination on land, surfacewater, and groundwater;

• Disturb permafrost;

• Change the number, size, and connectivityof thermokarsts along the ROW; and

• Remove geologic resources.

Conversely, the physical environment couldimpact the TAPS under the proposed action,less-than-30-year renewal alternative, andno-action alternative. Impacting factors on theTAPS could include:

• Earthquakes;

• Glacial movements (surges and retreats);

• Solifluction (i.e., a slow-motion debris flowcreated when a permafrost layer that hasreduced cohesive strength because ofsupersaturation moves slowly downhill);

• Mud flows;

• Global warming; and

• Geologic hazards, such as debris flows,landslides, rock falls, slumps, and floods.

These impacting factors could affect the TAPSby causing physical changes and accidentalreleases of oil or other materials, which, in turn,could then affect the environment in the waysdiscussed above.

Effects of the impacting factors on theenvironment under the proposed action and theless-than-30-year renewal alternative wereevaluated by interpolating impacts from existingconditions as a base case, historical ranges ofimpacts observed from more than 25 years ofoperation, and mitigation activities that havebeen implemented. If a potential impact of theproposed action would lie outside the historicalrange observed, the impact was evaluated byextrapolating historical impacts and theirmitigation and using engineering judgment. Thepotential impacts of the environment on theTAPS were assessed on the basis of existingand historical information and engineeringjudgment. Impacts were quantified, to the extentpossible, by making simplifying assumptions andusing analytical expressions, energy balances,and conservation laws (e.g., the total mass in asystem is constant).

Under the no-action alternative, the impactof dismantling and removing the TAPS andrestoring the ROW was evaluated on the basis ofhistorical impacts of TAPS construction,considering historical mitigation strategies. Ifnecessary, impacts were extrapolated fromhistorical information and engineering judgmentto account for impacts outside the range ofprevious activities.

Data used to evaluate the impacts ofgeology and seismology on the TAPS wereobtained from surface and bedrock maps of theunderlying strata along the ROW; historicalseismic monitoring information; literature on faultsystems crossed by the ROW; and, wherepossible, aerial photographs of sensitive regionsalong the ROW.

Information on soil and permafrost wasobtained from permafrost surveys, the scientificliterature, soil classification guides, proceedings

A-5 APPENDIX A

____________________________

1 The phrase �source terms� refers to the quantities and characteristics of contaminants released to theenvironment from specific sources or groups of sources.

of polar conferences, maintenance databases,documented historical mitigation activities, site-characterization data for known spill sites, andthroughput and accident source terms1

developed for this analysis by Argonne NationalLaboratory (Argonne) staff.

Data used to evaluate the hydrologicalimpacts included documentation on riversystems crossed by the ROW, U.S. GeologicalSurvey (USGS) databases on river flow,historical information on groundwater wellcompletions, historical data on water uses,National Pollutant Discharge Elimination System(NPDES) permits, and the open literature.Accident source terms (such as spill volumesand release durations) and cumulative sourceterms (i.e., releases from activities not related tothe TAPS that can impact the same resources)were developed by Argonne staff.

Source terms used in the impact analysesfor geology, seismology, soils, permafrost, andhydrology were obtained from the ArgonneOperations/Risk Analysis Group. Impactsevaluated by the Geology, Seismology, Soils,Permafrost, and Hydrology Group were suppliedto the following disciplines for their analyses:Ecology, Human Health, Cultural Resources,Atmospheric Sciences, and Coastal PlainManagement. In addition, the Geology,Seismology, Soils, Permafrost, and HydrologyGroup supplied information to theOperations/Risk Analysis Group for potentialaccident scenarios associated withenvironmental impacts on the TAPS(e.g., earthquakes, glacier movement).

A.3 Paleontology

Methods used in the assessment ofpaleontological resources focused on evaluatingthe potential disturbance of plant and animalfossils under the proposed action, the less-than-30-year renewal alternative, and the no-actionalternative. Paleontological remains areprotected under the Antiquities Act of 1906 (andother laws as indicated in Section 3.6), pendingmore focused legislation currently in preparation;

as a result, guidance on impact assessment isfairly general. The examination of impacts topaleontological resources ultimately relied onevidence of the existence, density, and nature offossil deposits in areas that might be disturbedunder the alternatives considered. However, theevaluation also considered the quality ofavailable data and the likely condition ofpaleontological resources. The latter factor wasbased largely on accumulated grounddisturbance from the more than three decadesspent constructing and maintaining the TAPS.The region of influence for paleontologicalresources includes the ROW and any areasaffected, or likely to be affected, by TAPSconstruction or maintenance.

The evaluation of impacts to paleontologicalresources required specific information on thoseresources. Critical data included depositlocation, assorted information in publications onpaleontological resources in the vicinity of theTAPS, data from researchers focusing on thepaleontology of Alaska, and information in filesmaintained by the State Historic PreservationOffice, the Bureau of Land Management (BLM),other federal agencies, and the Alyeska PipelineService Company (APSC). The analysis usedthis assortment of information to define wherepaleontological deposits occur; the age, depth,and spatial extent of each deposit; and the levelof disturbance of each locality. It also usedavailable data to understand the likelihood thatother paleontological resources occur inparticular locations, recognizing the specialpotential of sedimentary strata for such deposits.Finally, the analysis considered those portions ofAPSC procedures manuals dealing withpaleontological resource protection andmonitoring.

The assessment of potential impacts topaleontological resources involved identifyingthose activities that would result in surface orsubsurface disturbance within the region ofinfluence. Activities evaluated included TAPSmaintenance efforts that likely would disturbareas containing known paleontologicalresources or areas likely to contain suchresources. Impacts, in turn, were defined as the

APPENDIX A A-6

effect of anticipated activities on intact knownpaleontological resources. Other potentialsources of impacts included the effect ofincreased accessibility to intact paleontologicalremains and any effects resulting from spills andspill response-related activities. Of particularconcern were any impacts potentially affectingdeposits of vertebrate fossils.

Several disciplines provided data relevant tothe evaluation of impacts to paleontologicalresources. Geology and soils analyses providedinformation on the distribution of geologicalstrata, providing insight both on likely effects ofany spill in certain paleontological deposits andon areas with a high potential for undocumentedpaleontological resources. The hydrologicalevaluation, in turn, provided information onchanging waterways and the potential forerosion that might threaten paleontologicaldeposits. Personnel working on the TAPSmaintenance sections of the DEIS describedprocedures and activities associated with TAPSoperation that might disturb known fossildeposits.

A.4 Air Quality and Noise

A.4.1 Air Quality

Assessment of the potential air qualityimpacts for the proposed action, the less-than-30-year renewal alternative, and the no-actionalternative involved a multistep process thatincluded (1) collecting and organizinginformation on existing air quality andmeteorological conditions in the affectedenvironment; (2) identifying and quantifyingTAPS-associated air pollutant emissionssources for a range of activities under theproposed action, no action, and the less-than-30-year renewal alternative; (3) identifying andquantifying pollutant emissions from othersources in the affected areas; (4) usingcomputer models to estimate the dispersion ofTAPS-related emissions and their contributionsto ambient air quality; and (5) comparing resultsof the modeling to appropriate air qualitystandards.

Available meteorological data and ambientair quality measurements from instruments alongthe TAPS ROW were acquired for use indescribing the existing environment and as inputdata in modeling potential air quality impactsresulting from the proposed action and theno-action alternative. Data for meteorologicalparameters, such as surface data (wind speedand direction, temperature, humidity,precipitation, etc.) and upper-air data wereobtained from government agencies (e.g.,National Climatic Data Center) and industrysources. Ambient monitored and modeled datafor criteria and hazardous air pollutants wereobtained from the U.S. Environmental ProtectionAgency (EPA) and industry sources.

Basic information on emission sources andemission inventory data for the TAPS stationary,mobile, and fugitive pollutant sources that isessential in assessing potential air qualityimpacts were obtained from such documents asTAPS facility air permit applications submitted toand air permits issued by the Alaska Departmentof Environmental Conservation (ADEC) andenvironmental impact studies conducted byindustry.

Information on the extent of disturbed landareas and vehicle and heavy equipment usageassociated with maintenance and system-upgrade activities was obtained from industrysources. Data on the extent of land areadisturbed and vehicle and heavy equipmentusage that would be associated with terminationactivities under the no-action alternative weredeveloped in consultation with industryspecialists. Information previously developed forother similar projects was also obtained andused to the extent applicable.

To assess the significance of TAPSemissions relative to overall air quality,information and inventory data for otheremissions sources in the areas surroundingTAPS facilities were obtained from regulatoryagencies.

In assessing potential air quality impacts, anumber of assumptions were necessarybecause of the limitations of impact assessmentmodels or uncertainties in model input data. Inaddition to the general assumptions outlined in

A-7 APPENDIX A

Section A.1, the following specific assumptionswere made for the air quality impact analysis:

• Assessments of potential impacts weremade for (1) areas up to 30 mi from sourcesfor ambient air quality impacts of criteriapollutants, and (2) community boundaries forhazardous air pollutants.

• Assessments of potential impacts on air-quality-related values, such as visibility andacid deposition, were made for sensitivereceptors located within about 60 mi ofsource areas.

The following procedures were used toassess potential air quality impacts resultingfrom the proposed action and the no-actionalternative:

• Confirm or estimate emissions data forcriteria and hazardous air pollutants fromTAPS facilities and TAPS-related activitiesby reviewing available data or usingavailable emission factors and activitylevels.

• Estimate emission rates of hazardous airpollutants from accidental releases or spillsof crude oil, petroleum products, andhazardous materials by using the EPA-recommended procedures for estimatingevaporative emissions from mixturescontaining toxic liquids and water andsolutions of toxic substances (EPA 1999a;IT Alaska 2001).

• Assess the significance of TAPS-relatedemissions by comparing with emissions frommajor facilities in adjacent areas.

• Perform air dispersion modeling as neededby using EPA-recommended models, suchas the Industrial Source Complex Model(ISC3) (EPA 1995) for short- and long-termcontinuous emissions and the ISC3 or ArealLocations of Hazardous Atmospheres(ALOHA) Model (EPA et al. 1999) for short-term emissions from accidental releases.

• Compare modeled concentration incrementswith prevention of significant deterioration(PSD) increments.

• Identify appropriate backgroundconcentrations used in air quality impactmodeling studies conducted recently forTAPS facility emission sources.

• Add background concentrations to themodeling results and compare resultantconcentrations with National or AlaskaAmbient Air Quality Standards (NAAQS orAAAQS).

• Assess potential visibility and aciddeposition impacts at sensitive receptors byrelating recent trends in TAPS emissions tothose in available visibility and sensitive lakeacidity data at those sensitive receptorlocations.

Factors that would determine levels ofpotential air quality impacts would include theintensity, duration, and frequency of TAPSactivities that generate air emissions. Theseparameters were defined on the basis ofavailable information or were estimated inconsultation with industry specialists for normaloperations, routine maintenance activities,system upgrade activities, routine security andoil spill surveillance activities, and restorationactivities. These data then were used as inputfor impact modeling and assessments.

Certain basic information and results ofimpact assessments from other disciplinaryareas were needed to conduct air quality impactmodeling and assessments. The results fromthat modeling were in turn needed in conductingimpact assessments for certain other disciplinaryareas. Information to and from other disciplinaryareas for air quality was as follows:

• Transportation: Received current andprojected traffic volumes (ground, air, andmarine);

• Accidents: Provided meteorological data;

• Spills: Received projected information onpotential spills of crude oil, petroleumproducts, and hazardous materials; and

• Human health: Provided air dispersionmodeling results for criteria and hazardousair pollutant emissions.

APPENDIX A A-8

____________________________

2 Blasting is commonly conducted in sequences using delays. Thus, for any given delay, only a portion of the totalexplosive charge is set off to limit the potential impact to that of the portion rather than the total.

A.4.2 Noise

Intrusive noise can be continuous,intermittent, or impulsive depending on itsduration. Continuous or intermittent noise istypically generated by stationary sources, suchas boilers and diesel generators, and mobilesources, such as aircraft, vehicles, andconstruction equipment. Blasting that usesexplosives to demolish concrete structures aspart of termination activities under the no-actionalternative would produce impulsive noiseaccompanied by ground vibration and airblastoverpressure.

The methodology used to assess potentialimpacts on noise consisted of (1) collectingavailable information on background andambient noise measurements and noise studiesconducted in the vicinity of TAPS facilities;(2) collecting information on existing noisesources within and around the TAPS facilities aswell as on TAPS-related noise sources for theproposed action and the alternatives,(3) determining the locations of potentialsensitive receptors, and (4) modeling potentialnoise impacts for comparison with appropriatenoise guidelines.

Procedures used in assessing potentialimpacts of continuous or intermittent noise wereas follows:

• Compilation or estimation of sound-power orsound pressure level of individual noisesources along the TAPS ROW by using thedata available in the literature,

• Estimation of the potential noise impacts atTAPS facility site boundaries or nearbysensitive receptors by considering geometricspreading of sound energy through theatmosphere, and

• Assessment of potential noise impacts bycomparing resultant noise levels with EPAnoise guidelines.

The methodology used to assess potentialimpacts on ground vibration and airblastoverpressure consisted of (1) collectingavailable information on concrete structures tobe demolished at TAPS facilities under the no-action alternative; (2) collecting or estimatinginformation on the charge weight per delay,2

charge depth, and frequency and duration ofblasting; (3) determining the locations ofpotential sensitive receptors; and (4) modelingpotential impacts on ground vibration andairblast overpressure for comparison withappropriate guidelines.

Procedures used in assessing potentialimpacts on ground vibration and airblastoverpressure were as follows:

• Estimation of the potential impacts onground vibration at nearby sensitivereceptors by using a monograph (Rose1981) that relates the peak particle velocity(PPV), charge weight per delay, and thedistance between the blast and selectedreceptor. (The PPV or the velocity of groundmovement is generally accepted as the bestindicator of the potential for structuraldamage.)

• Assessment of the potential impacts onground vibration by comparing the resultantPPV with the PPV level of 2.0 in./s, which isgenerally accepted as safe for poor plaster(DOE 1990).

• Estimation of the potential impacts onairblast overpressure at nearby sensitivereceptors by using empirical formulas thatallow computation of peak overpressure at agiven receptor location for a blast of a givencharge weight per delay by correcting thepeak overpressure at the reference of 200 ftfrom 1.0 lb of charge exploded at groundlevel (Schomer 1973, 1981).

A-9 APPENDIX A

• Assessment of the potential impacts onairblast overpressure by comparingestimated peak overpressure with aconservative upper limit value (0.01 lb/in.2)below which no damage to farm or wildanimal was caused (Fletcher and Busnel1978).

Certain basic information and results ofimpact assessments from other disciplinaryareas were needed to conduct noise impactmodeling/estimation and assessments. Theresults of that modeling/estimation were in turnneeded in conducting impact assessments forcertain other disciplinary areas. Information toand from other disciplinary areas for noise wasas follows:

• Transportation: Received current andprojected traffic volumes (ground, air, andmarine); and

• Human health: Provided impactmodeling/estimation results for noise,ground vibration, and airblast overpressure.

A.5 Hazardous Materialsand WasteManagement

Stipulations contained in Part 2 of theFederal Grant require that all operations of theTAPS comply with relevant state and federallaws and regulations. Member agencies of theJoint Pipeline Office (JPO) have the necessaryauthority to interpret and apply thoserequirements to TAPS operations, in partthrough the issuance of operating permits, sitelicenses, or other enforceable instruments.Operating permits routinely require thecollection, maintenance, and, in some cases,submission of data to demonstrate the facility�scompliance with permit stipulations. Thesecompliance-related data are valuable indicatorsof both the nature and dimensions ofenvironmental impacts related to TAPS wastegeneration and management, and, whenrelevant, have been used in assessing impactsof the proposed action and the alternatives.

The APSC corporate strategy for compliancewith all applicable environmental regulations,

permit requirements, and Federal Grantstipulations is to establish and maintain acomprehensive environmental managementsystem that provides explicit guidance forsatisfaction of each applicable requirement. Theenvironmental management system comprises anumber of �business models,� each of whichestablishes strategic objectives, assigns rolesand responsibilities, and defines performanceindicators for a specific area of interest. Modelswith relevance for hazardous materials andwaste include water quality, waste management,environment response and remediation,hazardous materials management, fieldactivities, and records and documentation.

In most instances, the business modelsdirect the development of standard operatingprocedures to, among other objectives, ensurecompliance with applicable standards.Procedures controlling the acquisition, storage,and use of hazardous materials are contained inChapter 8 of the TAPS Environmental ProtectionManual, EN-43-1 (ASPC 1998a). Proceduresrelating to the transportation of hazardousmaterials by APSC and its contractors arecontained in APSC Manual HZ-134, Guide forPackaging and Transporting HazardousMaterials/Dangerous Goods by Highway and byAircraft (APSC 2001c).

Procedures that most directly relate to wastemanagement are incorporated into the TAPSEnvironmental Protection Manual, WasteManagement, EN-43-2 (APSC 2000).Procedures specific to the Ballast WaterTreatment Facility (BWTF) at Valdez MarineTerminal are contained in APSC ManualMP-69-1, Best Management Practices Plan,Ballast Water Treatment, Alyeska MarineTerminal (APSC 1998b).

APSC procedures also call for internalreviews of scheduled projects to define theirexpected environmental consequence andidentify applicable external regulatory or internalAPSC controls. These project reviews also arevaluable sources of information indicative ofaffected environments from TAPS operations.Such internal reviews can also be used to qualify

APPENDIX A A-10

and in some cases, quantify, the impacts ofTAPS operations on the environment.

The pertinent APSC business models andrelated procedures manuals, as well as datacontained in required compliance submissionsand environmental monitoring reports andobtained from implementation of internalstandard operating procedures, were used todescribe the use of hazardous materials inoperation of the TAPS and to define the natureand scope of TAPS-related waste managementand the associated impacts. The use of TAPSempirical operating data, especially data thathave been independently validated through JPOoversight, will result in the highest possiblelevels of accuracy and relevance. Success ofthis strategy relies on the validity of the followingassumptions:

• Adequate statutory authority exists foreffective oversight by JPO agencies;

• Relevant and enforceable regulations are inplace to control wastes resulting from TAPSactivities;

• Appropriate considerations of human healthand environmental risk are reflected incurrent grant stipulations, operating permits,and other controls;

• Appropriate commitment and resources existwithin the JPO to ensure continuing effectiveoversight of TAPS activities;

• APSC demonstrates a continuingcommitment to protect TAPS assets throughappropriate preventative maintenanceprograms and expeditious response tosystem failures, including accidental orunplanned releases of contaminants to theenvironment; and

• No significant changes to operatingconditions or reconfigurations of the TAPSare contained in the proposed action tocontinue the Federal Grant, notwithstandingfluctuations of oil throughput, changes madeto equipment necessary to meet minimumperformance standards, or changes resultingfrom the introduction of technologyadvancements, as approved by the JPO.

Identified environmental impacts associatedwith the generation and management of wastesare categorized as direct or indirect. Workingdefinitions and examples for each of thosecategories as they pertain to hazardousmaterials and waste management are as follows:

• Direct impacts: Impacts of wastes and wastemanagement activities resulting directly fromoperation and maintenance of the pipeline,pump stations, and the Valdez MarineTerminal. Examples include wastes from thecorrosion digs/corrosion repairs, recoveryand disposal of tank bottoms from pumpstations and Valdez Marine Terminal crudeoil storage tanks, and contaminated mediaresulting from accidental or unplannedreleases of crude oil.

• Indirect impacts: Impacts of wastes andwaste management activities related to theoperation of essential ancillary systems andfacilities. Examples include domesticsanitary wastewater and domestic solidwaste from pump station personnel livingquarters, maintenance of APSC vehicles,equipment refurbishment and repairactivities conducted at maintenance yards,and ash from incineration of solid wastes atpump stations.

The JPO has stipulated that the TAPS itselfends at the product discharge points of the oilloading arms at the Valdez Marine Terminaltanker berths. Consequently, ballast water that isremoved from tanker ballast tanks and deliveredto the BWTF for treatment is technically outsidethe TAPS, and ballast water management couldbe addressed as a cumulative impact. However,while the primary purpose of the BWTF is thetreatment of ballast water, it is also used to treatpotentially contaminated storm water originatingwithin the industrial areas of the Valdez MarineTerminal as well as condensates removed fromthe pipeline and from storage tanks and transferpiping within the Valdez Marine Terminal. Withrespect to those functions, therefore, the BWTFis an integral part of the Valdez Marine Terminaland is considered to be within the TAPS.Nevertheless, all wastewater delivered to theBWTF is commingled before treatment, anddifferentiating the environmental impacts of theBWTF between its treatment of variousidentifiable waste streams is not possible.

A-11 APPENDIX A

Consequently, it is appropriate to discuss theimpacts of the entirety of BWTF operations atone location within this DEIS. However, theBWTF�s operation is integral to the ValdezMarine Terminal operations and is discussed inSection 3.16 and Appendix C, and its impactsare addressed in Sections 4.3.12, 4.5.2.12,and 4.6.2.12. In addition, changes to ballastwater impacts because of tanker reconfigurationare addressed in Section 4.7.6.10, CumulativeImpacts Analysis.

The following data used to supportenvironmental impact analyses for direct andindirect activities were collected:

• Data supplied by APSC through itsAnchorage administrative headquarters andits Fairbanks and Valdez Business Units,including but not limited to:

− Copies of past and present operatingpermits,

− Compliance-related data submitted toappropriate JPO agencies in satisfactionof regulatory or facility-specific permitrequirements,

− Documentation related to the disposal ofAPSC wastes by commercial facilities,

− Monitoring data required to be maintainedby regulation or permit,

− Correspondence between APSC and theJPO relating to waste managementissues,

− Internal APSC monitoring data resultingfrom the execution of standard operatingprocedures, and

− Characterization studies of sites at whichaccidental or unplanned releases of oil orhazardous substances had occurred,

• Compliance-related documents supplied bythe JPO,

• Summary reports of unique APSC projects,and

• Personal communications withrepresentatives of JPO regulatory agenciesand APSC.

Many compliance-related documents are ofa recurring nature (e.g., annual reports ofdischarges under a NPDES permit or a BiennialResource Conservation and Recovery Act[RCRA] report of hazardous waste generationand management activities). For these, anumber of submissions in the sequence werereviewed to detect any significant trends. Whereno such trends were identified, the most recentsubmissions were deemed to be the mostrepresentative of APSC activities. Wheresubstantial changes had occurred over time withrespect to the volume or character of waste ortheir management, averages of the datacontained in an appropriate number of historicalsubmissions were used as the bestrepresentation of activity levels. Wastemanagement activities of APSC contractors arealso reflected in the APSC compliancesubmissions, even when those activities takeplace off the TAPS ROW. Consequently, neithercontractor data nor personal communicationswith contractor personnel were deemednecessary to capture contractor wastegeneration and management activities.

Compliance-related documents obtainedfrom APSC sources and the JPO were used tosupport environment impact assessmentsassociated with direct or indirect activities, thatis, the continuing operation of the TAPS.However, waste management documentationrelated to oil exploration and production at theNorth Slope (including both onshore andoffshore activities) were collected directly fromcompanies conducting those activities. Suchdocumentation was used to supportassessments of cumulative impacts.

For the no-action alternative, the historicalrecord of waste generation and impact duringinitial TAPS construction was identified aspotentially relevant, although not all wastesgenerated during construction would necessarilyreoccur during removal and restoration, asdefined by the JPO. In addition, the historicalrecord of pipeline reroutes and replacementswas reviewed for its potential relevance indescribing the nature and extent of wastes that

APPENDIX A A-12

can be anticipated during removal andrestoration activities.

Finally, information on volumes and types ofTAPS wastes and the manner in which they aremanaged will be provided for incorporation intoimpact analyses of natural ecosystems.

A.6 Human Health andSafety

Potential health and safety impacts toworkers and the general public were evaluatedfor normal operations and accidental releases.The following overview of the methodologyaddresses both the proposed action, the less-than-30-year renewal alternative, and the no-action alternative.

A.6.1 Proposed Action andLess-Than-30-YearRenewal Alternative

Two types of potential impacts areaddressed: (1) the industrial (physical hazard)risk and (2) the risk from chemical exposuresduring both normal operations and accidentalreleases at the pipeline releases.

A.6.1.1 Normal Operations

A.6.1.1.1 Occupational. The numbersof worker fatalities and injuries associated withcontinued operation and maintenance of thepipeline were estimated by using occupationalhazards statistics available from the Bureau ofLabor Statistics and the National Safety Council(NSC 2000, 2001). These projections were thencompared with the historical safety performancedata reported for normal pipeline operations.

Fatality and injury risks for recordableinjuries and those involving lost workdays werecalculated as the product of the appropriateincidence rate, the number of years foroperations, and the number of full-timeequivalent employees for operations. Thesecalculations of risks of fatality and injury fromindustrial accidents were based on historical

industrywide statistics and, therefore, do notconsider a threshold (i.e., any activity wouldresult in some estimated risk of fatality andinjury).

The analysis of physical hazards to workersrequired historical occupational hazard data fromAPSC and the JPO specifically annual fatalityand injury incidence rates and the number ofworkers by location over time.

Potential impacts of chemical exposures toworkers were not quantified for normaloperations and maintenance activities. It wasassumed that potential worker exposures tochemicals used in TAPS operations (e.g.,chemicals used at pump stations) wereaddressed by U.S. Occupational Safety andHealth Administration (OSHA) permissibleexposure limits (PELs) (OSHA 2001). Tomaintain compliance with OSHA standards, it islikely that chemical exposures would beminimized by various engineering mitigativecontrols (e.g., fume hoods and glove boxes andheating and ventilation designs for high-hazardareas) and extensive indoor air monitoring.

A.6.1.1.2 Public. The first step of thechemical exposure assessment for members ofthe public was to screen potential hazards ofchemical exposure along the ROW on the basisof estimates of the quantities released to air,water, or soil. If the screening phase revealedthat potentially significant chemical exposurescould occur to the general public during normaloperations, the associated risk was thenquantitatively assessed. When available,chemical concentrations in air, water, and/or soilwere compared with generic screening valuesthat correspond to a fixed level of risk to humanhealth. Chemical concentrations less than orequal to screening levels or below backgroundconcentrations were eliminated from furtherevaluation. The purpose of this human healthscreening approach was to identify anysignificant chemical contaminants and exposurepathways that might warrant quantitativeanalysis. The methodologies used inquantitatively assessing chemical risk andimpacts on human health from normaloperations and maintenance of the pipeline aredescribed below.

A-13 APPENDIX A

The evaluation of chronic health hazardsfocused on hypothetical maximally exposedindividuals (MEIs) of the general public. Becausethe standard methodologies for chemical healthrisk assessment do not usually involveassessment of collective (population) dose orrisk, population risk was not evaluated forchemical exposures (EPA 1989). However, if ahealth risk was shown to exist for the MEI,additional assessment was conducted toestimate the number of individuals likely to beaffected.

Chemical intakes and health risks fromrelevant exposure routes (e.g., inhalation) wereassessed when estimated releases from TAPSoperations exceeded screening values. Forexample, air dispersion modeling was conductedto estimate exposure media concentrations.Possible exposures for the MEI could includeinhalation of airborne emissions, incidentalingestion of contaminants deposited on soil, andingestion of contaminated water. Intake wassummed over the appropriate potential exposurepathways. Appropriate exposure factors(e.g., data on human behaviors andcharacteristics that affect exposure toenvironmental contaminants) for the variouspathways to be evaluated can generally beobtained from EPA guidance documents.

Risks from chemical releases are commonlyexpressed in terms of the �hazard quotient� forexposures to noncarcinogens (i.e., comparisonof estimated receptor doses with referencelevels or doses below which adverse effectswould be very unlikely to occur). Forcarcinogenic chemicals, the estimated averagedaily intake was multiplied by carcinogenicpotency factors to estimate increased lifetimecancer risks. The risks were then compared withthe risk range of 10-4 to 10-6 generally used toassess the significance of exposures tocarcinogens. Where possible, the referencelevels used to generate hazard quotients andcarcinogenic risks were obtained from the EPA'sIntegrated Risk Information System (IRIS) (EPA2001). If standard reference levels were notavailable, the existing toxicity literature wasreviewed to assess the potential hazard ofestimated exposures.

Whenever possible, the assessment ofchronic health hazards of chemical exposures to

the general public used quantitative estimates ofthe chemical concentrations in air, water, or soilthat were estimated in the medium-specificanalyses of the DEIS. If such information wasnot available, the assumption was generallymade that there was insufficient evidence forelevated media concentrations from normaloperation releases and, therefore, the potentialfor public health impacts was too low to beevaluated. Another important assumption wasthat physical hazards to the general public areminimized through restricted access to TAPSfacilities. It was also assumed that healthsurveillance (epidemiological) data are notavailable for documenting current health statusof the general public.

A number of types of data from otherdisciplines were needed for these assessments:(1) maximum air toxics levels (e.g., at pumpstations, Valdez Marine Terminal); (2) chemicalconcentrations in groundwater and surfacewater; and (3) residual chemical concentrationsin soil. Demographic data on nearest residencesand subsistence patterns were also needed.Data sources for evaluating chronic healthhazards of chemical exposure were mostly thosethat the other disciplines needed to estimatereleases and subsequent media concentrations(e.g., air toxics emissions data from the ValdezMarine Terminal and pump stations, BWTFeffluent discharge concentrations, anddemographic data).

A.6.1.2 Accidental Releases

A.6.1.2.1 Occupational. Becausehistorical safety hazard data were not compiledand reported for specific spill events, physicalhazards to workers during spill responses wereincluded in the overall data analysis of workerfatalities and injuries associated with ongoingoperations of the pipeline.

Potential impacts of chemical exposuresand/or physical hazards to workers were alsoaddressed by modeling a fire and explosion (foradditional information, see the fire analysis ofspill events in Section 4.4.3). The probability offire and explosion at the Valdez Marine Terminalwas estimated on the basis of historical data.Although highly speculative, estimation of the

APPENDIX A A-14

number of fatalities and injuries resulting fromthis scenario was also explored. However, it isassumed that potential exposures of workers tochemicals from a fire and/or explosion would beaddressed both through emergency responsecontingency plans and by compliance withOSHA standards for minimizing chemicalexposures using various engineering mitigativecontrols for high-hazard areas.

A.6.1.2.2 Public. This analysis primarilyaddressed the potential risk to the general publicof chemical exposures resulting from accidentalreleases at the pipeline. Because it is assumedthat spills onto gravel or soil surfaces would becleaned up according to regulations, thereshould be no long-term impacts to soil orexposure to contaminants in soil. Therefore, thefirst step was to confirm that no completeexposure pathways or elevated concentrationswould remain after remediation was completedat the land spill sites. Specifically, the risk-basedcorrective action approach that was conductedfor one of the larger spill sites was reviewed toensure that the ADEC Site ContaminationProgram has shown that spills to soil have notresulted in potential human health risks fromdirect contact or leaching to groundwater.

For spills to water, the potential for uptake ofpipeline-related contaminants into the foodchain, with subsequent ingestion of subsistencespecies by Alaskans, was evaluated.Specifically, if elevated concentrations ofpetroleum hydrocarbon constituents in fishtissue were found by the biological resourcesimpact analysis or in the literature, then ascreening analysis of fish ingestion wasconducted. This screening analysis of potentialhazards of chemical exposures to the generalpublic was based on the comparison ofincremental tissue concentrations ofcontaminants in fish to available screeningvalues (e.g., Alaska and national fishadvisories). Petroleum hydrocarbon-relatedcompound concentrations less than screeninglevels or below background concentrations wereeliminated from further evaluation. If furtheranalysis was warranted, then available Alaskan

dietary intake survey data were used to estimatepotential risks from fish consumption.

It was assumed that physical hazards to thegeneral public would be minimized throughrestricted access to TAPS facilities, includingfire/explosion scenarios modeled at the ValdezMarine Terminal. It was also assumed that anindoor explosion event (e.g., at pump stations,North Pole metering station) is improbablebecause of the relatively low probability ofoccurrence based on historical data, as well asfire protection systems in place.

Some data needed for these evaluations hadto come from impact assessments in otherdisciplines. For example, maximum fish tissueconcentrations of chemicals resulting from spillsto water bodies were necessary from thebiological resources analyses. The fire andexplosion modeling results were needed fromthe air quality accidents analysis. Demographicdata on nearby residences and information onsubsistence patterns were also needed. Datasources for evaluating chronic health hazards ofchemical exposure include those that wereneeded by biological resources for estimatingthe incremental uptake and subsequent fishtissue concentrations. An important source wasdata collected after the Exxon Valdez spillrelating to measured tissue levels ofcontaminants in fish species. Additional dataneeds included the level and duration of fish andwildlife advisories; Alaskan dietary intake surveydata; chemical constituents in crude oil andindustrial products used (including use ofproprietary chemicals and pesticides along theROW); risk characterization data for previousspill-contaminated sites; and ambient airconcentration measurements collected after theExxon Valdez spill.

A.6.2 No Action

The analysis of the no-action alternative ofnot renewing the Federal Grant of the TAPSROW, including dismantling and removing TAPSassets and restoring the environment, involvedsome of the same methodologies as describedabove for the proposed action. In particular, thehealth and safety analysis of the no-action

A-15 APPENDIX A

alternative focused mainly on deconstruction-related physical hazards to workers.

A.6.2.1 Occupational

The numbers of worker fatalities and injuriesassociated with pipeline termination activitieswere estimated by using occupational hazardsstatistics available from the Bureau of LaborStatistics and the National Safety Council (NSC2000, 2001). These projections were thencompared with the historical safety performancedata reported for the original pipelineconstruction project.

Fatality and injury risks for both recordableinjuries and those involving lost workdays werecalculated as the product of the appropriateincidence rate, the number of years foroperations, and the number of full-timeequivalent employees for operations. Thesecalculations of risks of fatality and injury fromindustrial accidents are based on historicalindustrywide statistics, for which any activitywould result in some estimated risk of fatalityand injury.

The analysis of physical hazards to workersused historical occupational hazard data, asavailable, specifically annual fatality and injuryincidence rates and the number of workers bylocation during the original pipeline constructionproject. Otherwise, fatality and injury incidencerates for the construction industry weresubstituted.

Potential impacts of most chemicalexposures to workers were not quantified for theno-action alternative. It was assumed thatresidual crude oil would be removed from thepipeline and that low-level emissions ofpotentially toxic air pollutants occurring from theuse of various chemicals during removal andrestoration would be minor. It was also assumedthat potential exposures of workers to chemicalsused would be addressed by OccupationalSafety and Health (OSHA) permissible exposurelimits (PELs) and engineering mitigative controls(e.g., personal protective equipment, PPE).However, levels of particulate matter generatedduring removal and restoration activities wereevaluated through comparison with health-basedstandards.

A.6.2.2 Public

Potential health impacts of most chemicalexposures to the general public were notquantified for the no-action alternative. It wasassumed that low-level emissions of potentiallytoxic air pollutants occurring from the use ofvarious chemicals during removal andrestoration would be minor. It was also assumedthat spills onto gravel or soil surfaces would becleaned up according to regulations, and,consequently, there should be no long-termimpacts to soil or exposure to contaminants insoil. However, levels of particulate mattergenerated during removal and restorationactivities were evaluated through comparisonwith health-based standards.

It was further assumed that physical hazardsto the general public would be minimizedthrough restricted access to areas whereremoval and restoration activities were occurringand, therefore, potential impacts were notquantitatively estimated for the DEIS.

A.7 Biological Resources

The biological resources assessmentevaluated the direct and indirect impacts of theproposed action, the less-than-30-year renewalalternative, and the no-action alternative onaquatic (freshwater, estuarine, and marine),terrestrial, and wetland (freshwater andestuarine) systems. Particular attention wasgiven to protected species and the habitats onwhich they depend. For the DEIS, protectedspecies considered included the following:

• Species and their critical habitats listed bythe federal government under theEndangered Species Act,

• Species of special concern listed by theState of Alaska and the BLM,

• Marine mammals (seals, sea lions, seaotters, and whales) protected by the MarineMammal Protection Act,

• Bald and golden eagles protected by theBald and Golden Eagle Protection Act, and

APPENDIX A A-16

• Essential fish habitat protected by theMagnusen-Stevens Fishery Conservationand Management Act.

The region of influence for direct and indirecteffects included the footprint of the 800-mi-longTAPS ROW and associated facilities included inthe Federal Grant. These associated facilitiesincluded the Valdez Marine Terminal, materialsites, disposal areas, previously contaminatedsites, and support facilities (e.g., airports, accessroads, and work camps). The region of influenceof indirect impacts also included adjacent areasthat would be affected secondarily by activitieswithin the project footprint. Examples includeareas adjacent to pump stations affected bynoise, the Dalton Highway (used to transportmaterials and people to various locations alongthe pipeline), areas affected by runoff from theTAPS workpad or other exposed groundsurfaces, and areas affected under various spillscenarios.

A conceptual impact model was developedto structure the assessment of impacts(Table A-1). This model identified impactingfactors associated with the proposed action, theless-than-30-year renewal alternative, and theno-action alternative environmental changes thatimpacting factors would produce, and thebiological resources that would be affected bythese changes. Impacting factors associatedwith the proposed action and the less-than-30-year renewal alternative include facilityexistence, normal operations, routinemaintenance and system upgrades, and spills.Impacting factors associated with the no-actionalternative would be the result of the terminationactivities needed to return the area to astablecondition and the natural succession thatwould proceed once termination activities werecompleted.

Environmental changes that would occur inresponse to these factors and that wereevaluated in the biological resourcesassessment included direct habitat modification,erosion of soils and sedimentation of areasreceiving runoff, changes in flow patterns,changes in water quality and temperature,impacts to permafrost areas and thedevelopment of thermokarst, contamination of

areas affected by spills, barriers to animalmovements, changes in air quality, disturbanceassociated with noise and human activities, andchanges in human access. In various ways,these changes affect habitat characteristics andthe species supported by these habitats.Changes in species composition, speciesdiversity, species distributions, and populationdensity can result from these environmentalchanges.

Facility existence refers to the physicalpresence of the TAPS and its associatedfacilities in the environment. The existence of theTAPS (even without operation or maintenance)affects biological resources. Existing facilitiesconsidered in the assessment included thepipeline, workpad, cleared areas of the ROW,the Valdez Marine Terminal, access roads,disposal sites, material sites, contaminatedareas, pump stations, and the gas fuel line thatsupplies gas to PS 1 to 4. Continued facilityexistence would result in an extension of existingimpacts of the TAPS into the future; theseimpacts would for the most part be limited to theROW and vicinity. Impacts of facility existenceinclude maintenance of habitat in an alteredcondition, changes in flow patterns resultingfrom either the impoundment of surface flows ordiversion of flows, erosion of unvegetated areas(e.g., the workpad) and the subsequentsedimentation of areas receiving runoff andassociated effects on water quality, modificationof permafrost areas, existing contamination ofareas affected by previous spills, barriers toanimal movements presented by the pipelineand associated roads, and continued increase inhuman access and its associated impacts (e.g.,noise, disturbance, and hunting).

Normal operations and routine maintenanceof the TAPS include oil pumping, transportationof materials and supplies, waste managementactivities, workpad and access roadmaintenance, security operations, routineinspections, vegetation control, revegetationactivities, and quarry operations at materialsites. Impacts of normal operations and routinemaintenance would be limited to areas alreadyaffected by facility existence. Only quarryoperations would be likely to involve actions inareas not currently affected.

A-17 APPENDIX A

TABLE A-1 Conceptual Model for the Effects of the Proposed Action,the Less-Than-30-Year Renewal Alternative, and No Action onBiological Resources

Impact Sources Environmental Changes Affected Biological Resources

Proposed Action and Less-Than-30-Year RenewalAlternativeFacility existenceNormal operationsRoutine maintenance and monitoringSystem upgradesSpills

No ActionTermination activitiesNatural succession

Habitat modificationMovement barriersChanges in flow patternsErosion and sedimentationNoise and disturbanceAir qualityIntroduction of exotic organismsWater quality and temperatureAlteration of natural permafrost patternsContaminationChanges in human access to remote areas

Terrestrial and vegetation wetlandsFishBirds and mammalsThreatened, endangered, and protected species

Environmental changes resulting fromnormal operations and routine maintenanceinclude habitat modification resulting fromvegetation control and revegetation activities;erosion and sedimentation from the workpad,access roads, disposal sites, and material sites;impacts to water temperature in areas where thepipeline is buried in and adjacent to streams;changes in permafrost patterns and theoccurrence of thermokarst resulting from thepumping of warm oil through the pipeline; noiseand disturbance resulting from human activities,especially at the pump stations, Valdez MarineTerminal, and Dalton Highway; potentialintroduction of exotic organisms from tankerballast water into marine environments; anddegradation of air quality by emissions at pumpstations, the Valdez Marine Terminal, andtransport vehicles along the Dalton Highway.

System upgrades include corrosion digs,pipeline reroutes, stream modifications, valvereplacement, and vertical support member(VSM) replacement. System upgrades couldresult in impacts in areas outside of the currentdisturbed areas of the ROW. Depending on thenature of the upgrade, any of the environmentalchanges identified in the conceptual model(Table A-1) could result.

Spills include the accidental release of anymaterial associated with pipeline operations; theassessment, however, focused on oil spills.Although the obvious effect of spills is related tocontamination of soil and water, spills can alsoresult in habitat modification, erosion andsedimentation, noise and disturbance associatedwith cleanup activities, degradation of air qualityresulting from the release of oil vapors, effectson water quality, and melting of permafrost.Spills could occur along the pipeline, at pumpstations, and at the Valdez Marine Terminal.

The no-action alternative would involve notrenewing the TAPS ROW Federal Grant. Uponexpiration of the Federal Grant, at least portionsof the TAPS would be removed, and theenvironment would be restored to some agreed-upon condition. This process referred to asdismantling, removal, and restoration couldaffect biological resources both during and afterthe activities. All of the environmental changesidentified in the conceptual model (Table A-1)could occur, but the direction of the impacts(beneficial or adverse) would, in some cases, bethe reverse of the direction of impacts under theproposed action. Environmental changesassociated with dismantling, removal, andrestoration of the TAPS include erosion and

APPENDIX A A-18

sedimentation from work areas, noise anddisturbance from human activities, release of airemissions (dust and vehicle exhaust) and effectson air quality, impacts to water quality from workin and adjacent to streams and other waterbodies, and possible contamination resultingfrom spills and treatment of waste. Thesechanges would occur during the dismantling,removal, and restoration process; eventuallythey would cease once restoration activitieswere complete. Over the long-term, the no-action alternative would eliminate impactsassociated with facility existence, normaloperations, routine maintenance, and systemupgrades.

Existing data and research were reviewed todetermine past TAPS impacts and describe thebaseline conditions that are presented in thedescription of the affected environment, as wellas to project the impacts of continued operationsof the pipeline under the proposed action. Thisapproach could be used because mostcharacteristics of the proposed action are withinthe scope of past activities. Activities that wentbeyond the scope of past actions (e.g., somesystem upgrades) were evaluated on the basisof the findings of past research.

The biological resources assessment wasspatially based and focused on the effects ofenvironmental changes on habitatcharacteristics (structure and function), foodresources, species composition, speciesdiversity, species distributions (includingmovement patterns), and populationcharacteristics (e.g., growth, reproduction,survival). Impact significance was predicted fromthe areal extent of change, including the projectfootprint and affected adjacent areas;characteristics of the area affected; themagnitude of the change (deviation from thebaseline) anticipated; the time period when theimpact would occur; the duration of impacts; thesensitivity of biological resources to change; andthe rarity and importance of affectedcomponents.

Spill scenarios were developed that wererepresentative of a range of spills (both in termsof consequence and frequency) that might occurduring pipeline operations. These scenariosincluded spills in areas where the consequencesto biological resources were especially

significant because of the sensitivity of theresources (rare or protected species or habitats).The analysis of spill impacts focused on directimpacts to vegetation and animals (resulting ineither mortality or changes in productivity),chronic toxicity effects (decreased survivorship,decreased reproduction, food chain effects), andindirect effects resulting from these changes(e.g., effects of organisms in higher trophiclevels or those dependent on affected habitats).The assessment of toxicity effects was based onan extensive review of the relevant literature,particularly studies of the effects of the ExxonValdez oil spill and experimental or actual spillsthat have occurred in terrestrial habitats andwetlands.

A number of data sources from federal,state, and environmental organizations wereused to describe the affected environment andsupport the biological resources assessment.Sources included, but were not limited to, theAlaska Department of Fish and Game (ADF&G),Alaska Department of Natural Resources,Alaska Natural Heritage Program, APSC, BorealPartners in Flight Working Group, Exxon ValdezOil Spill Trustee Council, National Oceanic andAtmospheric Administration, Marine MammalCommission, U.S. Army Corps of Engineers,Region 7 of the U.S. Fish and Wildlife Service(USFWS), U.S. National Marine FisheriesService (NMFS), and University of AlaskaMuseum. In addition, scientific literature onbiological resources of Alaska and on impactingfactors associated with construction, operation,maintenance, oil exploration, and revegetationwas reviewed.

Information on life histories, populationestimates, species distributions, and harvestsummaries were obtained from ADF&Gpublications, including the Wildlife NotebookSeries; game management unit reports; annualperformance reports; fish habitat assessmentreports; finfish management reports; and theCatalog of Waters Important for Spawning,Rearing, or Migration of Anadromous Fishes(ADF&G 1998).

Information on fish and wildlife resources ofAlaska was also obtained from reports producedby the American Cetacean Society (fact sheets),Exxon Valdez Oil Spill Trustee Council (updateson injured resources), USFWS (Cyber Salmon

A-19 APPENDIX A

and other reports), NMFS (stock assessments),and USGS (Alaska Land Characteristics DataSet).

Various mapping sources were also used fordistributional information on vegetation, fish, andwildlife. These sources included USFWSNational Wetland Inventory maps,Environmental Sensitivity Index Files for theNorth Slope and Prince Williams Sound,ecoregion maps, the Environmental Atlas of theTrans Alaska Pipeline System (APSC 1993), andEssential Fish Habitat maps developed by theNMFS.

Consultation with the USFWS and NMFS,pursuant to Section 7(a)(2) of the EndangeredSpecies Act [16 USC §1536(a)(2)], wasconducted as part of the Federal Grant renewalprocess. A biological evaluation (BE) for theproposed action that addresses impacts of theproposed action on listed species anddesignated critical habitat was prepared (BLM2002).

A.8 Economics

A.8.1 Introduction andBackground

The analysis of the economic anddemographic impacts of the proposed action, theless-than-30-year renewal alternative, and theno-action alternative used the Man in the ArcticProgram (MAP) model developed at theUniversity of Alaska-Anchorage Institute forSocial and Economic Research (ISER) (Bermanet al. 1986; ISER 1985). The MAP model hasthree essential components: an economicmodule, a demographic module, and a fiscalmodule.

The economic module is an economic basemodel that essentially divides the Alaskaeconomy into two forms of economic activity basic and nonbasic (or support) activities. Basicactivities are the key economic sectors that arethe source of economic growth in the economy;they bring in money from outside the state inexchange for the goods or services produced.These activities do not depend on other sectors

in the economy of the state as the source ofgrowth. All other activities in the state arecharacterized as nonbasic activities. Theysupport basic activities and are dependent onthem for their source of growth.

The demand for the goods or servicesproduced by the basic sector generates moneyfrom outside the state, and the resultingmultiplier effect on the economy of the stateaffects the nonbasic sectors in the stateeconomy as basic activities purchase goods andservices in local markets from nonbasic activitiesand as households with workers in theseactivities are hired. For example, oil produced inAlaska and transported to West Coast refineriesgenerates wages and salaries for oil productionworkers, pipeline transportation workers andmarine transportation workers, some of whomare based in Alaska. Oil sales also generatewages and salaries in the many industriessupporting these transactions, including utilities,pipeline maintenance contractors, andaccounting firms supplying the oil companieswith goods and services as the oil is pumpedand transported out of the state. Theprocurement of goods and services alsogenerates employment and wages and salariesin oil auxiliary industries in the state, such asthose producing specialized equipment andproviding environmental services.

The procurement of goods and services andwages and salaries in the oil sector and insupporting activities has additional effects on thestate economy. Oil production, transportation,and auxiliary industry employees spend theirwages and salaries in grocery stores, banks,utilities, hospitals, and other support facilitiesand services. The employees of these supportfacilities, in turn, spend their wages and salariesin other support activities. Money brought intothe state as a result of the initial purchase of oilfrom Alaskan oil fields continues to multiplythrough the economy of the state until purchasesare made outside the state or money flows intosavings, at which point the multiplier processstops.

The size of the multiplier effect varies amongindustries as a result of differences in the extentto which the various basic and nonbasic supportindustries purchase goods and services fromwithin Alaska. Changes over time in the

APPENDIX A A-20

composition of the state�s economy mean thatthe size of the aggregate multiplier for the statealso changes over time.

The MAP model characterizes 12 sectors inthe economy of Alaska as basic. The petroleum,seafood, mining, timber, and agriculture sectorsproduce commodities that are primarily forexport to other parts of the United States.Tourism and air cargo are also basic industriesselling services primarily to nonresidents ofAlaska. Each of these industries depends onout-of-state markets as the primary sources ofdemand for production of goods and servicesthat would not otherwise take place. Anadditional source of funds from outside the statethat contributes to the economy of the state isfederal government employment, includingmilitary employment. The portion of the AlaskaPermanent Fund that comes from earnings oninvestments made outside the state and incomeon assets and private pensions are alsoclassified as forms of basic activity. Moreinformation on the assumptions used to developthe MAP model and more details on the role ofeach of the basic sectors in the model can befound in Goldsmith (1997), Berman et al. (1986),and ISER (1985).

The demographic module contains twoelements. The age and sex distributions of thepopulation are combined with fertility andmortality rates in an age-cohort survivalframework to determine the natural increase inthe population. Estimates provided for theAlaska population are specified for both theAlaska Native and non-Native portions of thepopulation to capture differences in the birthrates across the two groups. Net civilianmigration to the state is estimated on the basisof Alaskan employment and income growthrelative to the United States as a whole. Rapidemployment growth in the state has historicallyattracted large numbers of in-migrants as thenew jobs have tended to be relatively highlypaid, particularly those in the oil sector.

The fiscal module estimates each majorsource of revenue at both the state and locallevel on the basis of the existing tax structureand measures of overall economic activity in thestate. The model also incorporates revenuesharing between the state and the various localgovernments and assumes that total government

revenues, plus any change in the balances ofstate financial assets, and including anyallocations from the Permanent Fund, are equalto total government expenditures at both thestate and local level.

A.8.2 Impacts of the ProposedAction, Less-Than-30-Year RenewalAlternative, and No-Action Alternative

After validation of the MAP model for use inthis DEIS, the model was used to produceforecasts for each of the variables likely to affectthe impact analysis results. These variablesinclude employment; personal income; grossstate product; oil revenues; and state, regional,and local revenues and expenditures. Sectoralemployment forecasts were also prepared forthe major sectors in the Alaskan economy,including petroleum, mining, seafood, tourism,international freight handling, forest products,and government.

The MAP model was then used to calculateeconomic and demographic impact data for theproposed action and the no-action alternative forthe state and for the six census areas andboroughs in the pipeline corridor region. Thisregion includes Anchorage, the Fairbanks NorthStar and North Slope Boroughs, and theSoutheast Fairbanks, Valdez-Cordova, andYukon-Koyukuk Census Areas. Impacts at theregional level were not presented at the samelevel of detail as those at the state level, and nodata were available for gross regional productand state and local revenues and expenditures.An analysis of potential national impacts wasalso developed. Table A-2 lists the parametersanalyzed for the proposed action and the no-action alternative, respectively.

The analysis also included an assessment ofthe impacts of potential accidents on theeconomy of the state and pipeline corridorregion. For TAPS ROW renewal, the analysisconsidered the impact of oil spills on propertyvalues in the pipeline corridor region and onoverall economic activity in the state in terms ofthe loss of oil revenues to the state and theconsequent impact on the Permanent Fund

A-21 APPENDIX A

TABLE A-2 Economic and Demographic Impact Parameters Examined for theProposed Action, Less-Than-30-Year Renewal Alternative, and No-ActionAlternative

State of Alaska • Population, including natural increases and migration

• Total employment, including direct TAPS employment, and overall employment levels in thestate

• Sectoral employment (the impact of TAPS on employment in other sectors of the Alaskaeconomy, such as seafood, tourism, air cargo, and government)

• Personal incomes in the state, including the role of the Permanent Fund Dividend

• Gross state product (a measure of overall economic activity)

• Fiscal impacts, including the impacts on state and local government revenues andexpenditures, the Alaska Permanent Fund, and state government employment

Pipeline Corridor Region • Population, including natural increases and migration

• Overall employment levels in the region

• Personal incomes, including the role of the Permanent Fund Dividend

National Economy • Domestic oil production and national security (comparison of North Slope production with

domestic oil production and impact of North Slope output on imports from other countriesover the renewal period)

• Federal tax revenues

• Transportation, in particular shipbuilding and tanker employment

• Overall economic activity

dividend. The impact of accidents that maypotentially occur in Prince William Sound as aresult of tanker accidents were assessed as partof cumulative impacts.

A.8.3 Data Sources

A significant amount of data currently existsin the MAP model. Additional data werecollected to update the state and regionaleconomic and demographic baselines in themodel.

Data needed to update the economicbaseline were obtained from publicly availablefederal and state databases. Federal sourcesincluded the U.S. Bureau of the Census,U.S. Department of Commerce, U.S. Departmentof Agriculture, and the U.S. Department ofTransportation. State data came from the Alaska

Department of Labor and WorkforceDevelopment, Alaska Department of Revenue,Alaska Department of Community and EconomicDevelopment, and Alaska Permanent FundCorporation. These data were used to validateforecasts of the key economic variables used inthe model for each year in the TAPS renewalperiod. Additional data came from oil companies,APSC, and other industry and academicsources.

Fiscal data required for impact analysisconsist of revenue and expenditure data for theState of Alaska and for local governments. Fiscaldata were collected from the relevantjurisdictions and from federal governmentsources. Data were also collected from State ofAlaska sources on oil revenues derived fromTAPS operations.

APPENDIX A A-22

Total population data and data by genderand age cohort, for the state and for the pipelinecorridor region, were used in the model, both toprovide estimates of the baseline population forthe TAPS renewal period and to provideestimates of in-migration that would occur withchanges in TAPS activities. These data camefrom the U.S. Bureau of the Census.

The assessment of the impacts of potentialaccidents used literature based on data fromprevious accidents, including the Exxon Valdezspill in Prince William Sound.

A.9 Subsistence

The methods used to evaluate subsistenceimpacts in this DEIS focused on how theproposed action, the less-than-30-year renewalalternative, and the no-action alternative mayaffect the customary and traditional acquisitionand use of naturally occurring renewableresources for personal or family consumption.

Subsistence is an issue of considerableimportance in Alaska, both to Alaska Nativesand non-Natives, where many rely on hunting,fishing, trapping, and collecting to provide food,clothing, construction materials, and other itemsnecessary for survival. Moreover, subsistenceplays a particularly crucial role in Alaska Nativesociocultural systems, helping to reaffirm socialrelations during both the acquisition andexchange of resources and to redefinesociocultural systems in times of increasingchange. For years, many have believed that theTAPS has had important impacts onsubsistence, primarily in disrupting migrations orotherwise affecting the availability of subsistenceresources and in providing access to othersseeking the same resources for other reasons(primarily recreational).

The region of influence for the subsistenceanalysis corresponded approximately to theaggregation of traditional harvest areas that mayhave been (or may be) affected by the TAPS.Communities in this region of influenceconsisted of 44 places anticipated to experiencedirect effects due to continued TAPS operation.

Residents in 11 of these places areexcluded from subsistence activities by federal

regulations that limit subsistence to rural places(as stipulated in the Subsistence ManagementRegulations for the Harvest of Wildlife onFederal Public Lands in Alaska [Office ofSubsistence Management 2001]).

The evaluation of subsistence attempted,when possible, to examine community-specificimpacts, and this formed the core of thesubsistence analysis. As necessary, thesubsistence analysis considered data presentedby Fishery Management Area or GameManagement Unit, although those units do notcorrespond to community subsistence areasand, strictly speaking, did not contribute to theexpansion of the region of influence forsubsistence.

Data for the evaluation of subsistenceimpacts included both quantitative andqualitative information. Quantitative datasupporting the subsistence analysis includedweight of subsistence resources taken, total fishand game harvested, and householdsparticipating in subsistence. The analysis for thisDEIS examined these types of data, if available,for each community or management area.Qualitative data for the evaluation of impacts tosubsistence similarly consisted of a range ofinformation, including oral summaries ofsubsistence patterns, activities, and harvestsover time; statements about game migrationpatterns; and summaries of seasonalsubsistence activities for particular AlaskaNative villages or groups.

In the absence of more complete, systematiccoverage of quantitative subsistence over time,the analysis combined available quantitative andqualitative information in a complementaryfashion. Nevertheless, it is important toacknowledge that incomplete data greatlycompromise what one can say definitively aboutsubsistence, the changes it has recentlyexperienced, the causes of these changes, andtheir possible direct or indirect relationships tothe TAPS.

The approach taken in this analysis was toexamine subsistence patterns in eachcommunity or harvest area. When the datapermitted, the analysis considered subsistencechange over time, in part to help identify anyrelationship with the TAPS and also to

A-23 APPENDIX A

understand how subsistence patterns haveevolved in recent years. The aim of the analysiswas to define changes in subsistence harvestsdue to a reduction in subsistence resourcesavailable, as a consequence either of decline inresource population or a change in resourcemigratory behavior. The analysis considered therange of resources harvested for subsistencepurposes in each community, recognizing thatpotential impacts under any alternative mightaffect different resources in a dissimilar manner.The focus of the analysis was mainlygeographic, depending on data availability toexamine community subsistence patterns orharvests in resource management units in theproximity of the TAPS. Hypotheses on changingsubsistence yields were evaluated throughinterviewing experts for traditional knowledge ofparticular areas or resources bothresearchers with particular geographic or topicalexpertise and people engaged in subsistenceactivities. For the no-action alternative, theanalysis explored anticipated shifts in economicactivity identified in the economic evaluation,using these changes as a basis for projectingshifts in subsistence activity in the region ofinfluence.

The factors that had an impact onsubsistence were those that reduced access tosubsistence resources. Main factors includedchanging migration patterns and declining gamepopulations. Each of these factors has possibleTAPS-related causes, and the analysisconsidered these as well as alternativeexplanations. One likely cause of subsistencedeclines is the Dalton/Richardson Highway, bothin supporting traffic that is disrupting themigration patterns of certain species and inproviding access to competitors for subsistenceresources. It is important to remember inevaluating subsistence impacts that althoughmany consider this road part of the TAPS, it isboth separate from the system and consideredpart of existing conditions. It is likely to remain inplace under any TAPS alternative considered inthis DEIS.

Subsistence impacts are closely linked tocertain other disciplines. Most notably, theecology analysis provided key information onmain subsistence resources and related impactsassociated with the TAPS. Similarly, the

recreation analysis provided insight onrecreational hunting and fishing harvests,yielding an appreciation for how competition forresources contributed to subsistence changes.The hydrology analysis revealed potentialimpacts on fish and other water-relatedsubsistence species, while the accident analysispresented scenarios that might affect water orterrestrial subsistence resources. The economicanalysis, in turn, provided a sense of how othereconomic opportunities might lead to reducedsubsistence activity.

A.10 SocioculturalSystems

The methods used to evaluate socioculturalimpacts focused on aspects of the proposedaction, the less-than-30-year renewal alternative,and the no-action alternative that particularlyaffect Alaska Natives and rural non-Natives.

Sociocultural system is a concept thatencompasses a broad range of characteristicsabout a particular group, including socialorganization, administration, economy, ecology,demographics, and cultural values. As a result,all of the concerns explored have implications forsome aspect of Alaska Native and rural non-Native sociocultural systems; a point made allthe more obvious because of the large numberof Alaska Natives living both in the State ofAlaska and in the vicinity of the TAPS. Otherdisciplines worth noting include those with aparticularly close relationship to Alaska Natives,such as subsistence, or those having particularimportance to Alaska Natives and rural non-Natives, such as economics. They also includeenvironmental justice, which has a specialimportance for Alaska Natives both because ofthe minority status and the frequent low-incomestatus of indigenous groups in the state.

Issues examined specifically undersociocultural systems comprise primarily thosetopics related to Alaska Natives that are notcovered elsewhere location, sociopoliticalcharacteristics, settlement patterns, and, wherepossible, more elusive concepts such as culturalvalues. The sociocultural analysis alsoconsidered certain characteristics of rural non-Natives that help distinguish them from the

APPENDIX A A-24

remainder of mainstream Alaskan and Americansociety, such as location, adaptive patterns, and(again, as possible) cultural values.

The region of influence for the socioculturalanalysis varies. This DEIS considered certainimpacts at the level of the entire state such aschanges in institutional-administrativeorganization that have affected all AlaskaNatives as a consequence of the Alaska NativeClaims Settlement Act. The study also examinedimpacts at the level of eight Alaska Nativeregional sociocultural systems intersected by orclose to the TAPS. Finally, the socioculturalanalysis examined individual communities likelyto experience direct effects under either theproposed action or the no-action alternative. Onthe basis of likely impacts on subsistence,employment, culture, and land selection, theBLM 2001 identified 21 communities asdeserving particular attention: Alatna, Allakaket,Anaktuvuk Pass, Chenega, Chitina, CopperCenter, Cordova (Eyak), Evansville, Gakona,Gulkana, Hughes, Manley Hot Springs, Minto,Nanwalek, Nuiqsut, Port Graham, Rampart,Stevens Village, Tanana, Tatitlek, and Tazlina.

Primarily because of their geographicproximity to the TAPS, this DEIS also consideredpossible sociocultural impacts to 23 additionalcommunities: Big Delta, Coldfoot, College,Copperville, Deadhorse, Delta Junction, Ester,Fairbanks, Fox, Glennallen, Harding-BirchLakes, Kenny Lake, Livengood, Moose Creek,North Pole, Paxson, Pleasant Valley, PrudhoeBay, Salcha, Tonsina, Two Rivers, Valdez, andWiseman.

Data requirements for the evaluation ofsociocultural impacts included both quantitativeand qualitative information. Quantitative datasupporting the sociocultural analysis includedpopulation data, Native regional corporationcharacteristics, and data on social problems,such as substance abuse and suicides.Quantitative data vary widely both in theiravailability over space and time and in theirreliability. The types of qualitative data employedin the assessment of sociocultural impactsincluded information on social organization,cultural values, economic activities, andadministrative structure; how these componentsof the Alaska Native and rural non-Native worldhave changed over time; and Alaska Native and

key informant impressions of how the TAPS hasaffected and would continue to affect thesesociocultural systems. Much of this informationcame from prior anthropological and sociologicalresearch. Some of the more detailed work datesback several decades, thereby providing avaluable historical perspective but often lackingin current insight. Once again, other disciplinesfocused on topics that are closely related tosociocultural systems, such as economics andsubsistence.

The approach used to analyze socioculturalimpacts was to examine the varioussociocultural systems over time in an effort toidentify changes in location, demographics,sociopolitical characteristics, and settlementpatterns of those systems; the degree to whichthe TAPS contributed to these changes; andlikely future changes. Two major challengeswere faced in evaluating sociocultural impacts.One was to identify the impacts to socioculturalsystems as defined above. The secondchallenge, no less important and in many waysmuch more daunting, was to isolate thoseimpacts partially or totally associated with theTAPS recognizing that Alaska Nativesociocultural systems in particular haveexperienced considerable change throughoutmuch of the past century. Ultimately, impactswere associated as possible with the proposedaction or the no-action alternative. Identifyingeffects related to the TAPS, and the probableprocesses underlying their emergence, makes itpossible to propose likely impacts of any of thealternatives.

The factors that lead to sociocultural impactstend to involve major components ofsociocultural systems such as the economy as well as interaction with other, differentsociocultural systems. Increased involvement ina cash economy and the growing opportunities,challenges, and frustrations of this involvementhave been proposed as sources of key impactson Alaska Natives. Growing interaction with non-Natives and the increased socioeconomicdisparities between Alaska Natives and non-Natives have been seen as contributing to socialpressures and resulting social ills such assubstance abuse and suicides. Ultimately,impacting factors associated with the proposedaction and the alternatives are determined

A-25 APPENDIX A

through empirical examinations of thesociocultural systems affected by the TAPS andhow these systems have changed over time,both in key characteristics (location,sociopolitical organ, and others noted above)and in the emergence or increase in social ills.

As noted above, certain other disciplineswere particularly important in the examination ofpotential sociocultural impacts. Subsistence, ofconsiderable importance to rural Alaskans ingeneral and especially important to AlaskaNative culture, provides not only a source ofnutrition and other materials, but also plays acentral role in social organization and themaintenance of social relations.

Economics, which has importantimplications for all Alaskans in the context of theTAPS, assumes perhaps a more important rolefor Alaska Natives and rural non-Natives whooften fall below the poverty level and for whomsources of cash income often are fewer than fornon-Natives and nonrural residents. However,virtually all other disciplines in this DEIS haveimplications for sociocultural systems,particularly for Alaska Natives given therelatively large number in the state and theirbroad geographic distribution. Nevertheless,because they were not exclusively socioculturalin nature, these other impacts are best dealt withunder other disciplines, with the Alaska Nativeand rural non-Native components identified aspossible and necessary.

A.11 Cultural Resources

The methods used to evaluate impacts tocultural resources focused on assessing thepotential disturbance to archaeological sites,historic structures, and traditional culturalproperties under the proposed action, the less-than-30-year renewal alternative, and theno-action alternative. As noted below, theassessment of impacts to cultural resourcesrelied primarily on National Register of HistoricPlaces (NRHP) eligibility status, eitherdetermined or potential. However, the evaluationalso considered the quality of the available dataand the condition of cultural resources (basedlargely on current levels of ground disturbance).The region of influence for cultural resources

includes the ROW and any additional areasaffected, or likely to be affected, by TAPSoperation or maintenance.

The evaluation of impacts to culturalresources required specific information on thoseresources. Archaeological sites, traditionalcultural properties, and historic structures withinthe region of influence were identified andassessed on the basis of site locationinformation provided by the Alaska State HistoricPreservation Office, archaeological surveyreports associated with the original constructionof the TAPS and all later clearancerequirements, architectural survey reportsidentifying historic structures, and general textson the historic and prehistoric materials andproperties found along the ROW and associatedactivity areas.

For each cultural resource within the regionof influence, the above materials also providedinformation on the type of site, NRHP status (ifdetermined), level of disturbance, sacred status,age, depth, and spatial extent. The project teamconsulted the State Historic Preservation Officerto confirm NRHP status, discuss potential futuredeterminations of NRHP status, and identify anyparticular preservation issues or problemsassociated with specific cultural resources.Other information used included APSCprocedure manuals on cultural resourceprotection and background information onpipeline technology to assess the potentialhistorical importance of the TAPS itself.

The assessment of potential impacts tocultural resources involved identifying thoseactivities that would result in surface orsubsurface disturbance within the region ofinfluence. Activities evaluated includedmaintenance that would likely disturb areascontaining known cultural resources. Impacts, inturn, were defined as the effect of identifiedactivities on intact known cultural resources. Theidentification of impacts relied on GIS-basedoverlays, emphasizing either co-occurrence orgeographical proximity of potential disturbanceto known resources. Other potential sources ofimpacts included the effect of increasedaccessibility to intact cultural remains and anyeffects resulting from spills and spill responseactivities.

APPENDIX A A-26

Several disciplines provided relevant data.Geology and soils studies provided informationon soil types and the effect that a spill wouldhave on soils. Erosion was a concern during theanalysis, primarily because of the number ofwaterways that the TAPS crosses that couldalter archaeological resources. Consideration oferosion was also important in assessing theeffects of spill removal on cultural resources.Hydrology studies provided information onchanging waterways and the resulting erosion.Personnel working on the pipeline maintenancesections of this DEIS provided information onprocedures and activities in place for the pipelinethat were needed to identify potential impacts.

A.12 Land Use and CoastalZone Management

A.12.1 Land Use

The TAPS and associated facilities arelocated primarily on federal and state lands, withabout 10% on private lands. In addition tovarying land ownership of the ROW itself, landuse also varies in the vicinity of the TAPS;potential uses are often related closely toownership. The methodology used to assessimpacts to land use considered anticipatedchanges under the proposed action, less-than-30-year renewal alternative, and no-actionalternative, focusing in particular on major landuse categories and how these would likelychange.

This analysis assumed that the region ofinfluence for land use consisted of the areawithin the ROW that varies from about 54 ft tomore than 100 ft wide, and areas near the ROWthat experienced past TAPS-related land useeffects. It was also assumed that under theproposed action, no-action alternative, and less-than-30-year renewal alternative, the DaltonHighway would remain open to the public andthe existing airports in the utility corridor wouldremain. The analysis assumed that recent trendsin land use change would provide a reasonablebasis for projected future conditions and impactsunder the proposed action.

The primary data used to support theanalysis of land use impacts consisted ofinformation on existing land ownership and usepatterns within the TAPS region of influence, aswell as prior patterns of ownership and uses the latter to establish trends in land use changeover time. The analysis used quantified land usedata when possible, consistent with theappearance of many of these data in map form.Ownership and use maps included the State ofAlaska TAPS Lease Renewal Project Map ofExisting Leases and Permits (ADNR 2001) andthe Environmental Atlas of the Trans AlaskaPipeline System (APSC 1993). In addition,applicable land use plans were identified andreviewed, as discussed further below. Argonnestaff contacted government officials and privatelandowners to obtain supplemental informationand to collect additional information on use andownership patterns in areas where suchconfigurations were unclear. Applicable federaland state statutes and regulations providedinformation on locations and types of permittedand restricted activities in the region of influence.

The evaluation of land use impacts used aphased approach. It began with the definition ofcurrent (recent) land ownership and usepatterns, as well as prior configurations, toprovide the basis for any impact analysis.Special status lands, such as state parks,National Parks, National Wilderness Areas, andNational Wildlife Refuges, were also identified.The analysis then determined (when possible)trends in land use change during the last25 years and projected these into the future tosupport an analysis of the proposed action andless-than-30-year renewal alternative.

Impacts under the no-action alternative, inturn, were projected on the basis of results of theeconomic analysis, notably the negativeeconomic impacts anticipated in the region ofinfluence (and elsewhere in Alaska) if the ROWwas not renewed. Impacts on land use fromtermination activities were also considered.DEIS team members reviewed existing federal,state, and local land use plans to determineconsistency with the continued operation of theTAPS and its (TAPS) removal and restoration.Federal plans included the river managementplans for the Delta National Wild and ScenicRiver and Gulkana National Wild River

A-27 APPENDIX A

(BLM 1983a,b), Utility Corridor ProposedResource Management Plan and FinalEnvironmental Impact Statement (FEIS)(BLM 1989), Dalton Highway Recreation AreaManagement Plan (BLM 1991); ManagementFramework Plan for the South Central PlanningArea (BLM 1980); and Fort Greely ProposedResource Management Plan FEIS (BLM andUSARAK 1994).

State plans included the Tanana Basin AreaPlan for State Lands (ADNR 1991); CopperRiver Basin Area Plan for State Lands (ADNRand ADF&G 1986); Prince William Sound AreaPlan for State Lands (ADNR and ADF&G 1988);and Dalton Highway Master Plan (DaltonHighway 1998). Local plans included theFairbanks North Star Borough ComprehensiveMaster Plan (Fairbanks North Star Borough1999), North Slope Borough ComprehensivePlan (North Slope Borough 1983), and ValdezComprehensive Plan (City of Valdez 2000).

Private land use plans and data also werereviewed and analyzed, as available. In allcases, the evaluation of land use impactscompared anticipated changes in land useconfigurations with current configurations andwith stipulations of current land use plans todetermine levels of effect throughout the regionof influence.

The analysis of land ownership and useshared key links with several other disciplinesconsidered in this DEIS. Land use affectsaesthetics, just as visual resource managementobjectives may dictate land use. In addition,recreation, wilderness, subsistence, andtransportation corridors are all types of land use;each is addressed in a separate section.Suitable land use is determined by acombination of elements related tosocioeconomics and the physical environment,including topography, geology, ecology, andwater resources. Because of the potential effectsof a TAPS-related accident on current and futureland use under the alternatives, the examinationof various spill scenarios played a key role in theanalysis of potential land use impacts. Impactdeterminations for accident scenarios werelargely based on the results of the spill analysesfor hydrology and ecology.

A.12.2 Coastal ZoneManagement

The TAPS begins and ends in Alaskancoastal zones. One hundred ten miles of thepipeline and related structures are encompassedin the North Slope Borough coastal zone whereTAPS originates, and 25 miles of the pipelineand the Valdez Marine Terminal are within theValdez coastal zone. The federal Coastal ZoneManagement Act (CZMA) of 1972 (amended in2001) and the Alaska Coastal Management Act(ACMA) of 1977 (amended in 1994) regulateactivities in Alaskan coastal zones, including theTAPS. The ACMA is implemented by the AlaskaCoastal Management Program (ACMP)(approved in 1979), which encourages coastaldistricts to develop and adopt district coastalmanagement programs (CMPs) that becomepart of the ACMP once they are fully approved.All activities, including those related to theTAPS, that occur within the coastal zone or thatmay affect coastal resources must be consistentwith the enforceable policies in an approvedCMP. Both the North Slope Borough and Valdezcoastal zones have approved CMPs. Themethodology for evaluating coastal zone impactsfor the proposed action, less-than-30-yearrenewal alternative, and no-action alternativefocused on their potential effects on coastalresources and their consistency with applicablestatewide ACMP standards and the enforceablepolicies in the North Slope Borough and ValdezCMPs.

The coastal zone analysis focused on datathat emphasized the identification of existingpermitted activities, enforceable policies, andapplicable statewide standards within the NorthSlope Borough and Valdez coastal zones andthe evaluation of all alternatives in this DEIS interms of these criteria. The analysis usedquantitative data whenever available to supportthe impact analyses. In addition to theinformation available in the North Slope Boroughand Valdez CMPs, the data used for theanalyses covered impacts identified by otherdisciplines but occurring in a coastal zone. TheDEIS team contacted personnel from the AlaskaDivision of Governmental Coordination forsupplemental data on currently permitted

APPENDIX A A-28

activities. The CZMA, ACMA, and ACMP werealso reviewed.

Potential impacts on both CMPs under theproposed action, less-than-30-year renewalalternative, and no-action alternative wereanalyzed in terms of the types of activitiespermitted in the two coastal zones of interest.The analysis focused on the magnitude andspatial distribution of any potential impacts andidentified impacts that would result fromactivities under the alternatives that would not beconsistent with CMP-enforceable policies orapplicable statewide standards. Analysis of theno-action alternative assumes that terminationactivities would occur in both the North SlopeBorough and Valdez coastal zones over a six-year period.

The coastal zone analysis shared links withseveral other disciplines in this DEIS. Permittedactivities within the coastal zone affect theaesthetics of the area, and CMP-enforceablepolicies regarding aesthetics affect whichactivities are allowed, as well as associatedmitigation measures. Recreation, subsistence,commercial and industrial development, andtravel were important activities in coastal zoneswith associated CMP-enforceable policies andstandards. Because a TAPS-related accidentcould potentially affect a variety of permittedactivities in the coastal zone, spill scenarioswere analyzed to determine coastal zoneimpacts. Impact determinations for accidentscenarios were largely based on the results ofthe spill analyses for hydrology and ecology.

A.13 Recreation,Wilderness, andAesthetics

A.13.1 Recreation

Recreational resources are abundant on thestate and federal public lands in the vicinity ofthe TAPS. Some of the existing recreationalopportunities include hiking, camping, boating,fishing, trophy hunting, floating, and wintersports. The methods used to assess potentialimpacts to recreational resources under theproposed action, the less-than-30-year renewal

alternative, and the no-action alternativeconsidered how renewing or not renewing theTAPS ROW would affect the range ofrecreational opportunities available near thepipeline.

For purposes of this analysis, recreationalresources consisted of designated recreationalareas within a few miles of the TAPS where thelevel of use may have been affected by theconstruction and operation of the TAPS and itsassociated Haul Road. The region of influenceencompasses federal and state lands, includinga federally designated Wilderness Area, aNational Wild and Scenic River (the Delta River),and a National Wild River (the Gulkana River).The analysis of the alternatives assumed thatthe TAPS Haul Road north of Fairbanks (DaltonHighway) would remain open to the public andthat the existing airports in the utility corridorwould remain as well. Under the alternatives, theanalysis assumed that past trends provided areasonable basis for projecting future conditionsand impacts.

Recreational resources were identifiedwithin the region of influence. Particularconsideration was given to BLM recreationalopportunity spectrum (ROS) classifications andmanagement objectives for the lands near theutility corridor. The actual evaluation of impactson recreation focused on changes in ROSclasses. Levels of use were evaluated on thebasis of permit data as well as other usestatistics compiled by the managing governmentagencies. Current use statistics wereextrapolated to project potential impacts torecreational resources under the proposedaction. Although quantitative data wereemployed when possible, the analysis did notdiscount the value of qualitative information,particularly in the form of opinions from variousexperts. Appropriate government officials werealso interviewed to obtain descriptions of currentconditions of recreational resources and theirexpected future levels of use.

In addition, existing recreationalmanagement plans were reviewed to determineconsistency with both TAPS renewal and the no-action alternative. These plans included the rivermanagement plans for the Delta National Wildand Scenic River and the Gulkana National WildRiver (BLM 1983a,b); Utility Corridor Proposed

A-29 APPENDIX A

Resource Management Plan and FinalEnvironmental Impact Statement (BLM 1989);Dalton Highway Recreation Area ManagementPlan (BLM 1991); and Management FrameworkPlan for the South Central Planning Area(BLM 1980). Finally, various scenarios wereanalyzed to determine the potential impacts ofspills on recreational resources and the ROS inthe region of influence. Impact determinations foraccident scenarios were based primarily on theresults of the spill analyses for hydrology andecology.

The analysis of recreational resources waslinked to several other disciplines. Visualresources affect the types of recreationalopportunities available, just as the number andtype of recreational activities occurring affectvisual resources. Land use dictates whichrecreational opportunities are available, whereasthe demand for a particular recreationalexperience or facility dictates important aspectsof land use. Changes in transportation modesaffect access to recreational resources, withmovement by road, air, boat, or foot all providingvarying levels of access. Given the nature ofrecreational resources in the vicinity of theTAPS, ecology was of particular concern influencing both the availability of recreationalopportunities and the quality of the recreationalexperience. Depending on the level of use,recreational activities in turn also affectecological resources. Because TAPS-relatedaccidents could potentially affect a variety ofrecreational opportunities, the recreationanalysis was closely coordinated with the spillanalysis.

A.13.2 Wilderness

No designated or proposed state or federalWilderness Areas exist within or adjacent to theTAPS corridor. However, one federallydesignated Wilderness Area is located within afew miles of the TAPS. Wilderness, as definedby the Wilderness Act of 1964, is a primitive area�. . .untrammeled by man, where man himself isa visitor who does not remain� [16 USC§1131(c)]. Wilderness Areas offer outstandingopportunities for solitude and primitiverecreation, are at least 5,000 acres in size, andmay contain ecological or other values that

contribute to the designation. The methodologyfor identifying potential impacts to federallydesignated Wilderness Areas near the TAPSfocused on analyzing the effects to the qualitiesthat qualify the area for wilderness designation.Any ecological impacts are identified asdiscussed in Section A.7 (Biological Resources).

The Alaska National Interest LandsConservation Act (ANILCA) of 1980 alsogoverns wilderness in Alaska. Specifically,ANILCA exempts Alaskan wilderness from themotorized vehicle prohibition established by theWilderness Act of 1964. This exemption wasconsidered in determining potential impacts towilderness.

State-designated wilderness in Alaska israre, and no state statute exists for such adesignation. However, lands within state parksmay be designated as wilderness by the AlaskaLegislature. Currently, only two state parks aredesignated as wilderness in Alaska, and bothare more than 100 mi from the TAPS. No statedesignations for wilderness are currentlypending in legislature (Mylius 2002).

As noted above, the TAPS ROW corridordoes not pass through any designated orproposed state or federal wilderness areas (BLM1989). However, a federally designatedWilderness Area within Gates of the ArcticNational Park and Preserve (NPP) is in theproximity of the TAPS. Important assumptionsunderlying the analysis of the proposed action,less-than-30-year renewal alternative, andno-action alternative are that the Dalton Highwaywould remain open to the public and that theexisting airports in the utility corridor wouldremain. The potential environmental effects onboth designated and proposed WildernessAreas, including those related to access, wereassessed, as were potential impacts from theno-action alternative, which involves six years oftermination activities. Past trends provided abasis for predicting future changes in keyvariables.

Data were compiled and analyzed to assessthe existing condition of the federally designatedWilderness Area in the vicinity of the TAPS andto analyze potential wilderness impacts from thealternatives. Maps showing Wilderness Areasprovided basic information on location and

APPENDIX A A-30

configuration, both key considerations given theimportance of geographic proximity to potentialsources of impact. Government officials alsoserved as key sources of information. Theanalysis relied on quantifiable data wheneverpossible.

The evaluation of impacts to WildernessAreas analyzed potential impacts to the valuesthat originally qualified the Wilderness Area fordesignation. In particular, potential impacts to itsprimeval character, opportunities for solitude andprimitive recreation, the ecological or othervalues for which it was designated, and itsoverall size were analyzed. Because noWilderness Areas are within or adjacent to theTAPS, no direct impacts were identified. Impactswere indirect or cumulative, as in the event of aspill. Because of the potential effects of spills onwilderness values, the spill analyses played aparticularly important role in the evaluation ofWilderness Area impacts. Impact determinationsfor accident scenarios were largely based on theresults of the spill analyses for hydrology andecology.

A.13.3 Aesthetics

Aesthetics, also called visual resources, arerelated to landforms, water, vegetation, animals,and structures. The aesthetics along most of theTAPS are both outstanding and complex afunction of the 800-mi length of the TAPS in asetting known for stunning natural beauty. Abouthalf the length of the TAPS is above ground andclearly visible from the air. The majority of theabove-ground components are also visible fromadjacent public roads (TAPS Owners 2001c).The methodology used to identify current visualresources and potential impacts to aestheticsaimed to examine this complex visual setting ina systematic manner by characterizing aestheticresources present and assessing impacts underthe proposed action, less-than-30-year renewalalternative, and no-action alternative. Allconsiderations of aesthetic impacts recognizethat the pipeline is in place and is part of thebaseline condition.

The visual resources analysis in this DEISincluded considerations of land, water, animals,vegetation, and structures. One importantassumption underlying the analysis of these

resources under all of the alternatives was thatthe Dalton Highway would remain open to thepublic and that the existing airports in the utilitycorridor would remain. The region of influencefor the aesthetics analysis was specified as theviewshed, or localities visible from the TAPSROW (and vice versa).

Data from selected key sources wereanalyzed to assess the existing condition ofvisual resources and to assess potentialaesthetic impacts under all alternatives. Visualresource management plans were reviewed forthe areas where such plans exist (see below). Inparticular, this DEIS considered BLM visualresource management (VRM) classifications andobjectives for the utility corridor. Officials fromseveral government agencies were interviewedto complement written information. In addition todefining visual resources, VRM classifications,and management objectives, the evaluation ofaesthetics impacts included a review of digitaltopographic data and consideration of existingvisual resource mitigation measures.

Under the proposed action and the less-than-30-year renewal alternative, the evaluationof aesthetic impacts examined long-termimpacts associated with the continuation ofTAPS operation over 30 years or less. For theno-action alternative, the analysis evaluatedboth short-term (6 years of termination activities)and long-term impacts. Under the alternatives,the analysis began by defining the viewshed tofocus attention on the appropriate geographicarea. Within the utility corridor, the evaluationidentified and plotted VRM classifications andobjectives. In addition, it examined existingresource management plans that addressaesthetics to determine consistency with thecontinued operation of the TAPS and the no-action alternative.

Pertinent plans included the rivermanagement plans for the Delta National Wildand Scenic River and the Gulkana National WildRiver (BLM 1983a,b); Utility Corridor ProposedResource Management Plan and FEIS (BLM1989); Dalton Highway Recreation AreaManagement Plan (BLM 1991); ManagementFramework Plan for the South Central PlanningArea (BLM 1980); and both the Federal Grantand State Lease for the TAPS ROW. Theseplans provided a basis for assessing likely

A-31 APPENDIX A

impacts under the proposed action, less-than-30-year renewal alternative, and no-actionalternative in the region of influence. A numberof factors contributed to the degree to which theTAPS could affect the public viewshed, includingthe distance of the ROW from roadways andpublic areas, the topography, and vegetation.

The evaluation of aesthetics consideredanalyses in several other disciplines. Visualresources affect the types of recreationalopportunities available in the vicinity of theTAPS, just as the number and type ofrecreational activities occurring affectsaesthetics. Land use, wilderness, transportationcorridors, vegetation, and air quality all affectaesthetics notably landscape and viewingdistance. Conversely, aesthetics affect how landis used. Lastly, the aesthetics analysis alsoconsidered the range of accident scenariosexamined in this DEIS and relied heavily on theresults of the spill analyses for hydrology andecology to determine potential aesthetic impactsof a spill.

A.14 EnvironmentalJustice

The methods used to evaluate impactsrelative to environmental justice emphasizeissues identified in Executive Order 12898,which defined environmental justice as a topicrequiring evaluation in federal actions. Thisanalysis is focused on the identification of anyhigh and adverse impacts to low-income andminority populations as a consequence of theproposed action, the less-than-30-year renewalalternative, and the no-action alternative. Theimpacts examined include those identified in allother individual disciplines considered in thisDEIS. For example, impacts identified in theeconomic analysis are examined to see if theyhave environmental justice implications. Asnoted below, one discipline of particular concernin this study is subsistence. A topic of potentialconcern identified in the original executive order,subsistence is of particular interest in thepresent study because of the high reliance ofrural populations in Alaska (often low-income)and Alaska Natives (minority and also often low-income) on food acquired by fishing, hunting,and collecting.

Minority and low-income populations aredefined as follows:

• Minority Individuals who classifythemselves as belonging to any of thefollowing racial groups: Black (includingBlack or Negro, African American, Afro-American, Black Puerto Rican, Jamaican,Nigerian, West Indian, or Haitian); AmericanIndian, Eskimo, or Aleut; Asian or PacificIslander; or �Other Race� (CEQ 1997). In the2000 census, many individuals categorizedthemselves as belonging to more than onerace. This DEIS considers individuals ofmultiple races to be minority, regardless ofthe races involved. This study also includesindividuals identifying themselves asHispanic in origin, technically an ethniccategory, under minority. To avoid double-counting, the analysis included only WhiteHispanics, the above racial groups alreadyaccounting for non-White Hispanics.

• Low-Income Individuals falling below thepoverty line. For the 2000 census, thepoverty line was defined by a statisticalthreshold based on a weighted average thatconsidered both family size and the ages ofindividuals in a family. For example, thepoverty threshold annual income for a familyof five with one child younger than 18 yearswas $21,024, while the poverty threshold fora family of five with three related childrenaged less than 18 years was $19,882(U.S. Bureau of the Census 2000). If a familyfell below the poverty line for its particularcomposition, the census considered allindividuals in that family to be below thepoverty line. Low-income figures in the 2000census reflect incomes in 1999, the mostrecent year for which entire annual incomeswere known at the time of the most recentcensus.

The region of influence for environmentaljustice varies by impact area, ranging from theentire state of Alaska to geographic areas nearthe TAPS. Because the environmental justiceevaluation relied heavily on analyses in otherdisciplines, it also incorporated the assumptionsunderlying those other inquiries.

Although a certain logic suggests a greatersusceptibility of environmental justice

APPENDIX A A-32

populations to many environmental impacts,perhaps because of less access to key nutrientsor medical care than the population as a whole,presently there is no evidence of such differingvulnerability. As a result, the evaluation ofimpacts in terms of environmental justicegenerally assumed that minority and low-incomepopulations respond to various impacts in thesame manner as the population as a whole.Disproportionality therefore was used primarilyas a geographic concept to define places withparticularly high percentages of minority andlow-income populations. Disproportionately highpercentages are those that exceed thepercentage of low-income or minority persons inthe state of Alaska as a whole. The exception tothe assumption that impacts affect all personssimilarly are economic impacts because of percapita payments of the Permanent Funddividend. Minority and low-income populations inAlaska, commonly with larger families thanfound in nonminority and non-low-incomepopulations in the state (and thus receivinggreater total payments), would experiencedisproportionately high impacts should thedividend be discontinued.

The data used to evaluate impacts related toenvironmental justice were of two types: censusdata used to define disproportionality and dataon anticipated effects under the proposed action,the less-than-30-year renewal alternative, andthe no-action alternative. Data from the mostrecent decennial census of population andhousing, conducted in 2000, provided a recent,detailed basis for evaluating the distribution ofminority and low-income populations.

This DEIS analysis examined minority andlow-income populations with census datacollected and presented for two differentdemographic units: census block groups andcommunities. Census block groups are clustersof census blocks (the smallest geographic unitused by the Census Bureau) generallycontaining 250 to 550 housing units, with theideal size being 400 housing units. Becausehousing densities vary considerably, blockgroups cover a wide range of geographic sizes,with those in rural Alaska, which contains veryfew people and few houses, geographically quitebroad. Individual communities include bothincorporated places and census designated

places, the latter defined by the Census Bureaufor purposes of data collection and presentation.Communities were selected in part on the basisof their geographic proximity to the TAPS, whichwould increase the likelihood of theirexperiencing TAPS-related impacts undernormal operations, and in part on the basis oftheir inclusion on a list of directly affected placesdefined by the BLM (2001). This DEISconsidered environmental justice impacts to atotal of 44 individual communities. Through theuse of these two different geographic units, theenvironmental justice analysis wasgeographically commensurate with analyses intwo other disciplines having importantenvironmental justice implications humanhealth (which used block groups) andsubsistence (which used communities). Althoughthe economic analysis, which also has importantenvironmental justice implications, used largeranalytical units (boroughs and census areas)than the environmental justice analysis, becausethe block groups aggregate to these largerentities, direct comparisons can be made withthe economic impacts.

Environmental justice is not, in itself, animpact area per se. Rather, it encompassesother impacts that are both high and adverseand that affect minority and low-incomepopulations disproportionally. As such, theresults of assessments in these other disciplineswere crucial in the evaluation of environmentaljustice; they essentially preceded theenvironmental justice evaluation.

Because of the reliance of environmentaljustice assessments on analyses in otherdisciplines, the actual methods used to evaluateenvironmental justice were those used in thevarious other analyses. Although all otherdisciplines were of concern, of particularimportance were those three with importantimplications for minority or low-incomepopulations: human health, economics, andsubsistence. Because of the relationshipbetween environmental justice and otherdisciplines, impacting factors generally werethose associated with the analyses in otherdisciplines.

A-33 APPENDIX A

____________________________

3 The term spills as used in this appendix refers to unplanned or accidental releases of crude oil or other potentiallyhazardous materials to the environment. The spilled material can be in a liquid or vapor phase and/or occur as asecondary aerosol or gas formed in a crude oil fire or transformed to gases or aerosols in the atmosphere fromthe release of reactive or volatile hydrocarbons.

A.15 Spills (Accident)AnalysisMethodology

A.15.1 General Spills Analysis

A.15.1.1 Introduction andBackground

The main objective of the spills3 analysis isto estimate the frequency, quantity, and timedependence (e.g., instantaneous or prolonged)of unplanned releases of crude oil andpotentially hazardous substances to theenvironment. Spill frequency, size, and durationare jointly considered in formulating accidentalrelease scenarios used in estimating theenvironmental risk discussed in this DEIS.

The scenarios are designed to cover the riskthat may be associated with a variety of spillsthat could affect sensitive environmental media,such as, surface and subsurface soils,groundwater and surface water resources, andthe air. Included in the assessed impacts are therisk of damage or harm to plants, animals, andpeople that depend on and/or come in contactwith resources contaminated by the postulatedevents. In addition to potential crude oil spills,releases involving refined petroleum products,including diesel fuel, jet turbine fuel, andgasoline, were also assessed. Whereappropriate, hazardous materials used in theoperation of various TAPS facilities, such assulfuric acid and sodium hydroxide use at theValdez Marine Terminal power plant, wereconsidered in the postulated spill scenarios.

The scope of the spills analysis covers theentire TAPS, from production before thebeginning of the pipeline (Milepost [MP] 0) totanker loading and shipment at the end of thepipeline (MP 800). The potential impacts or riskof spills from TAPS operations from PS 1 toMP 800 at Valdez Marine Terminal and from theValdez Marine Terminal through tanker loading

were treated as part of the proposed action torenew the Federal Grant of ROW lease. Impactsassociated with the North Slope oil fields andpipelines up to the boundary of PS 1 and thetransport of the petroleum from loading berths atValdez Marine Terminal to approximately 15 mipast the Hinchinbrook Entrance to PrinceWilliam Sound (about 78 nautical miles from theValdez Marine Terminal) were treated under thecumulative impact section of this DEIS. The riskof spills connected to decommissioning,removal, and recovery activities for the TAPSwere assessed under the no-action alternative.Under no action, it is assumed that all oilproduction at the North Slope would stop. Theonly crude oil that could potentially be releasedto the environment under such conditions wouldbe crude left in the pipelines and storage tanks.The no-action alternative scenarios wereevaluated by using data obtained from the TAPSconstruction period to estimate the quantities ofresidual products (diesel fuel, gasoline, heatingoil, etc.) released to the environment.

The approach described in Section A.15.1.2on developing the spill scenarios does notaccount for what would be expected in acomprehensive spill response, nor should thedeveloped scenarios be regarded as predictionsof specific spill response procedureperformance. The developed scenarios wereintended for use in quantifying the potentialmagnitude of the environmental impactsassessed and reported in this DEIS. Actual spillresponses would be tailored to the existing siteconditions and the requisite responserequirements.

The methodology used in developing spillscenarios required careful consideration of thetype of oil that could be spilled in the proposedcontinued operation of the TAPS or in removaland restoration activities should the TAPS ROWgrant not be renewed.

Oil can be divided into five broad classes onthe basis of its physical and chemicalcharacteristics and the possible toxicity,damage, or injury to humans and natural

APPENDIX A A-34

resources from exposure to spilled product orcontaminants and/or contaminants evaporatedfrom the original liquid state. Pertinent propertiesof each oil class are summarized in Table A-3.Two of the five types correspond to refinedpetroleum product used during pipelineoperations.

Crude blends vary greatly in their chemicalcomposition, depending on the geographicallocation of their origin and the particularcompounds mixed with the petroleum products.Surfactants, often added to aid transport, willaffect physical properties when spilled. TheTAPS uses drag reducing agent as a throughputenhancing surfactant.

Hydrocarbons are by far the most abundantcompounds in crude oils, accounting for 50 to98% by volume. All crude blends contain lighter�fractions� of hydrocarbons (e.g., gasoline) aswell as heavier tars and wax-like hydrocarbons.

North Slope crude blends are Type 3 oilproducts and are considered medium grade. TheBritish Petroleum North Slope crude from PS 9has a relatively high viscosity (23.9 cSt at 50°F)and an American Petroleum Institute (API) ratingof 29.6 (NOAA 2001b).

On the basis of their characteristics, Type 1and Type 2 oils have differing direct effects onliving organisms. Gasoline is more acutely toxicthan diesel products, but evaporates faster.Diesel readily emulsifies in water, increasing itsviscosity and its volume, while gasoline does notemulsify. Both types of products tend topenetrate the substrate rather than adhere to thesurface.

A.15.1.2 Formulation andDevelopment of SpillScenarios

The first step in formulating the spillscenarios analyzed in this DEIS was to identify arepresentative range of accident scenarios andthe associated source terms for the spillsanalysis by grouping or classifying potential spillevents by frequency and associated magnitude.This process involved selection of four frequencyclassifications that would cover spills ranging

from those that would be considered as high-frequency, low-consequence events, to spillsconsidered extremely low in frequency but ofpotentially high consequence. The frequencyclassification scheme chosen is summarized inTable A-4. Spill events grouped in the high orintermediate frequency categories areanticipated or likely spills that have occurredover the operational life of the TAPS. They havea spill occurrence of one or more times per yearor one or more times over the original ROWlease period. It is reasonable in considering thehistorical record to assume that spill events inthese two categories would be anticipated at asimilar frequency or would likely occur over theproposed 30-year TAPS ROW renewal. The lasttwo categories are low or extremely lowfrequency events that are unlikely or veryunlikely to occur during the renewal period forthe TAPS.

The Exxon Valdez oil spill that occurred inPrince William Sound in 1989 would beconsidered a catastrophic event (a marine spillof greater than 250,000 bbl of crude). All of theother spills into Prince William Sound since1977, in comparison, would be considered small(less than 60 bbl). Over 90% of these spillsinvolved less than a barrel of oil, with around60% of the total less than a gallon. Because ofthe scheduled phaseout of single-hulled tankers,shipments of North Slope crude by double-hulledtankers as a percentage of tanker shipmentvolumes will increase from 38% in 2004 to 100%in 2014. Although the Exxon Valdez spill didoccur during TAPS operations, because of theresulting and anticipated changes in tankeroperations and design and in consideration ofthe risk assessment associated with futuretanker operations in Prince William Sound (PWS1999), repetition of such an event would still beconsidered extremely unlikely within theproposed grant renewal period.

Data on spill frequency, quantity, andduration from the TAPS historical record andrelevant engineering information on the TAPSsystem were collected, reviewed, and analyzed.A total of around 80 �credible� spill or accidentrelease scenarios (with likelihoods greaterthan 10-6) were developed and sorted into thefour frequency classes identified in Table A-4.

A-35 APPENDIX A

TABLE A-3 Types and Properties of Oil

Type 1 very light grade oils (gasoline) • Highly volatile and soluble

• Evaporates quickly, often completely within 1 to 2 days

• High acute toxicity

Type 2 light grade oils (jet fuels, diesel, No. 2 fuel oil, light crude) • Moderately volatile

• Will leave residue (up to one-third of spill amount) after a few days

• Moderately soluble, especially distilled products

• Moderate to high acute toxicity; product-specific toxicity related to type and concentration ofaromatic compounds

Type 3 medium grade oils (most crude oils) • About one-third will evaporate within 24 hours

• Typical water-soluble fraction 10−100 ppm

• May penetrate substrate and persist

• May pose significant cleanup related impacts

• Variable acute toxicity, depending on the amount of light fraction

Type 4 heavy grade oil (heavy crudes, No. 6 fuel oil, bunker C) • Heavy oils with little or no evaporation or dissolution

• Water-soluble fraction typically less than 10 ppm

• Heavy surface contamination likely

• Highly persistent, long-term contamination possible

• Weathers very slowly, may form tar balls

• May sink depending on product density and water density

• May pose significant cleanup related impacts

• Low acute toxicity relative to other oil types

Type 5 low API fuel grade oils (heavy industrial fuel oils) • Neutrally buoyant or may sink, depending on water density

• Weathers slowly; sunken oil has little potential for evaporation

• May accumulate on bottom under calm conditions and smother subtidal resources

• Sunken oil may be resuspended during storms, providing a chronic source of shoreline oiling

• Highly variable and often blended with oils

• Blends may be unstable and the oil may separate when spilled

• Low acute toxicity relative to other oil types

Source: Adapted from NOAA (2001a).

APPENDIX A A-36

TABLE A-4 Event Frequency Classifications

Event Likelihood Frequency Class Consequence

High frequency (anticipated)Events anticipated to occur one or more times every few years f > 0.5 per year Small

Intermediate frequency (likely)Events that are likely to occur once or more during the ROWrenewal period

0.03 < f < 0.5 Moderate

Low frequency (unlikely)Events that are unlikely to occur during the ROW renewal period (10-4 < f < 0.03) Large

Extremely low frequency (very unlikely)Events that are extremely unlikely to occur but, if they occurred,could have severe consequences

(10-6 < f < 10-4) Very large orsevere

Initiators that could generate a spill withlikelihoods less than 10-6 were by definitiondeemed �incredible� events and therefore notconsidered for further analysis. The scenarioscovered potential failures and associatedfrequencies in the major TAPS systemcomponents and subcomponents that couldoccur from a broad range of accident initiators(see Section A.15.1.5 for further discussion).Included were event causes (internal initiators)ranging from human error and failures in systemsubcomponents (e.g., check valves, corrosionand fatigue in the pipeline) to spills caused byexternal initiators such as earthquakes,landslides/avalanches, aircraft crashes,tsunamis, wildfires, flooding, and vandalism orsabotage.

The major TAPS components covered in theanalysis included the main-line pipe, pumpstations, crude oil tanks and tank farms, andloading berths. Subcomponents consideredincluded pipeline gate and check valves,pipeline controls (e.g., leak detection,telecommunication, remote gate valve system),and the metering stations. In addition to potentialcrude oil releases to the environment, othermaterial releases considered included refinedpetroleum products (e.g., gasoline, diesel fuel,turbine fuel, oils, and jet fuel), drag reducingagent, and other system-related chemicals (e.g.,sulfuric acid).

A.15.1.3 Spill Analysis Output

For each of the scenarios, the quantity andrate of material released (the source term) wereestablished as functions of pipeline operatingassumptions or crude oil throughput(see discussion in Section A.15.1.4). Sourceterms were established for affected TAPSsystem components or subcomponents. Avariety of system parameters and assumptionswere required, including failure modes (e.g., pipecorrosion hole size, location on pipeline ofguillotine break initiated by an external event),pipeline static and dynamic pressure andtemperature, and other design and/or operatingparameters (e.g., tank capacity). In some cases,the source term may be given as a range ofvalues or as different amounts released fordifferent locations along the pipeline. The timedependence and mode of release were alsofactored into the established spill scenarios.Although the most common or likely mode ofrelease considered was a liquid crude oil spillalong the pipeline, other release modes, such asan explosion, fire, and evaporation from a liquidspill, were also considered. Most of thescenarios were characterized as continuousreleases over a finite duration or instantaneous,such as a vapor cloud explosion.

A-37 APPENDIX A

A.15.1.4 Major Assumptions

One of the key assumptions necessary forestimating potential future crude oil spill ratesand spill volumes is a reasonably reliableforecast of pipeline throughput, typicallyexpressed in millions of barrels of crude oil perday (bbl/d). The TAPS Emergency Preparednessand Contingency Plan is based on a throughputof 1.5 million bbl/d (APSC 2001a). The plan usedestimates of spill volumes in accordance with theState of Alaska Planning Standard and usedAPSC�s TAPS Spill Program to estimate spillvolumes assuming this throughput. Historicalthroughputs over the past 10 to 15 years haveranged from around 1.0 million to2.1 million bbl/d, the maximum design capacitythroughput for TAPS. Since 1988 the averageannual throughput has declined steadily, asshown in Figure A-1. The Environmental Report(TAPS Owners 2001a) referenced theU.S. Department of Energy (DOE) forecast ofthroughput that indicated a steady decline ataround 4.2% per year for the next 18 years andthen assumed a leveling off at around0.49 million bbl/d through the end of the pipelineproposed action for ROW renewal through 2034.A daily throughput of around 0.7 million bbl/dwas observed in October 2001, but projectionsof the annual average for 2001 are expected tobe around 1 million bbl/d.

The DOE Energy InformationAdministration�s (EIA�s) Office of Oil and Gas,Reserves and Production Division, publishesannual updated data and forecasts of future oilproduction for the North Slope. The last reportincluded a range of plausible productionscenarios for the North Slope area of Alaska(DOE 2001). These scenarios were based on thedecline of existing production, the anticipatedstart-up of identified field development projects,and future discovery and development of theremaining undiscovered oil resources estimatedfor the area by the USGS, the BLM, and theMinerals Management Service (MMS). The EIA�s30-year projections (2004 through 2034) showthat crude oil production from existing producingand developing oil fields of the North Slope plusfuture production potential from three otherareas (two in the National Petroleum Reserveand the Central North Slope) show a declinefrom around 1 million bbl/d in 2004 to around

200,000 bbl/d by 2034. The average over this30-year projection period is 703,000 bbl/d.Figure A-2 shows the trend in total North Slopeoil production projections along with thecontributing projections from each fourproducing or potentially producing areas.Included in the figure is the 300,000 bbl/dnumber identified in the EIA report as theminimum operating volume or throughput lowerlimit. The TAPS maximum design capacity is2.1 million bbl/d.

To limit the spill scenarios to a reasonablenumber, three throughput assumptions wereused: the TAPS maximum design capacity of2.1 million bbl/d, the minimum economicallybased operating value of 300,000 million bbl/d,and a base-case value of 1.1 million bbl/d thatwould represent a more likely throughput forcontinued operation of the TAPS. Thesethroughputs provide upper and lower bounds tothe spill scenarios analyzed in this DEIS, alongwith a value that would be consideredrepresentative of future operations.

In addition to throughput, the spills analysisassumed that all tankers loading crude at theValdez Marine Terminal and shipping crudethough the Prince William Sound would bedouble-hulled after May 2013. A recent reviewby the National Research Council (1998)concluded that double-hulled tankers are four tosix times less likely than single-hulled tankers tospill oil in a vessel collision or grounding thatpenetrates the outer hull. The National ResearchCouncil estimated that the expected or averageoutflow is three to four times less with a double-hulled vessel compared with a single-hulled tankvessel and that the probability of a spill would bereduced by a factor of 4 to 6. Expected spillvolume would be reduced by factor of 3 to 4.

Scenarios involving leaks from the pipelineunder current operating controls and with leakdetection systems in operation would allow smallleaks to go undetected at a rate of 3,000 to6,000 bbl/d (under slack line conditions) foraround 4 to 7 days. Where practical, the spillscenarios and the assessed impacts gave creditfor spill containment and cleanup actionsconsistent with records of TAPS historical spillresponse and cleanup, as coordinated from theAPSC Fairbanks office and their SERVS unit atthe Valdez Marine Terminal.

APPENDIX A A-38

JKA50210

1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000

0.0

0.5

1.0

1.5

2.0

2.5

Oil

Pro

duct

ion

(mill

ion

bbl/d

)

Year

FIGURE A-1 North Slope Crude Oil Production from 1988 to 2000

JKA50211

2004 2009 2014 2019 2024 2029 2034

0

0.4

0.2

0.6

0.8

1.0

1.2

Oil

Pro

duct

ion

(mill

ion

bbl/d

)

Year

Current Producing

Central Area

Northeast NPR-A Area

West NPR-A Area

Total North Slope

FIGURE A-2 Projections of North Slope Crude Oil Production

A-39 APPENDIX A

A.15.1.5 Data Used in theSpills Analysis

As mentioned above, the high andintermediate frequency spill events wereidentified from the historical TAPS spill record.Several available existing databases werereviewed, including the ADEC and APSC datareferenced in the Environmental Report (TAPSOwners 2001a). The database, known as theOperations Oil Spill database, was the primarysource of data used in developing spill scenarioswith high and intermediate recurrencefrequencies. The database, originally compiledby the TAPS Spills Database (TAPS Owners2001b) with amendments and verification byArgonne, was updated with spill data for theperiod August 1999 through October 2001.Refinements to these spill scenarios anddevelopment of the low and extremely lowfrequency scenarios were made with the aid ofseveral TAPS-related system and systemcomponent risk assessments. A snapshot fromthe spills database is given in Figures A-3and A-4, which show the crude oil spill frequencyby the major TAPS segments and by spill sizegroupings. The data reveal that the majority ofthe spills over the TAPS lifetime have occurredin the North Slope, with around 20% equally splitbetween the pipeline and Valdez MarineTerminal spills. Almost 80% of the spills were inquantities of less than a barrel.

Where necessary, additional sources of datawere collected to help identify creditableextremely low frequency events. The Trans-Alaska Pipeline System Risk Assessment(Technica 1991) was one of the morequantitative of the risk assessments reviewed.An update to that assessment was inpreparation, but the final report was not availablein time for full consideration in developing thespill scenarios. Other risk assessment studiesconsidered in formulating scenarios were thoseconducted for the major pipeline components,including the North Slope, Valdez MarineTerminal, and Prince William Sound, and forsome of the systems subcomponents. Some ofthese studies are listed below:

• Risk Analysis Screening Study for the Trans-Alaska Pipeline System (Taylor andAssociates 1995);

• Prince William Sound, Alaska RiskAssessment Study, Final Report (DetNorske Veritas et al. 1996);

• Trans-Alaska Pipeline System Primary BlockValve Risk Assessment (Malvic and Weber1997);

• Estimation of Oil Spill Risk from AlaskaNorth Slope, Trans-Alaska Pipeline, andArctic Canada Oil Spill Data Sets (Mach etal. 2000);

• Valdez Marine Terminal Oil Spill RiskAssessment (Emerald Consulting Group2001);

• 10 Pipeline Valves with Leak-Through RiskAssessment (Aus et al. 2001); and

• Risk Assessment, Trans Alaska PipelineSystem, Final Report (Capstone 2001).

Information sources for development of thespill scenarios included the risk assessments,systemwide and component emergencypreparedness and response plans, the TAPSROW Environmental Report, and other relateddata. The data and assumptions used for spillanalysis in this DEIS were coordinated throughinteractions with the JPO and APSC engineers.Discussions covered reliability of systemcomponents, corrosion and metal fatigue data,historical incident databases, plans for dragreducing agent use, and transportation dataalong the pipeline.

A.15.1.6 Impacting Factors orEvent Initiators

The accident scenarios covered bothinternal and external initiating events. Theinternal initiators considered included spillscaused by equipment failure in valves, pumps,turbines, or tanks; human error; and agingeffects, including corrosion and metal fatigue.Traffic accidents were covered under humanerror. External initiators covered naturalphenomena, such as earthquakes, lightningstrikes, floods, and climate change. Eventscaused by an aircraft crash into the pipeline orinto a storage tank were also assessed as

APPENDIX A A-40

JKA50208

Pipeline 10%

Valdez Marine Terminal 11%

Tanker 14%

North Slope 65%

FIGURE A-3 Spill Frequency by TAPS Segment

JKA50209

<1 <42 <100 <250 <500 <1,000 <10,0000

200

400

600

800

1,000

1,200

1,4001,398

414

58 7824

1,600

Num

ber

of S

pills

Spill Size (bbl)

176 152

FIGURE A-4 Number of Spills by Size over TAPS Lifetime

A-41 APPENDIX A

external initiators or impacting factors. Finally,acts of vandalism, sabotage, or terrorism werealso considered as initiators.

A.15.1.7 Links toEnvironmentalResource ImpactDisciplines

The output of the spills analysis consists ofsource terms or accidental environmentalreleases used in support of risk assessmentsconducted for other disciplines or environmentalimpact areas covered in this DEIS. Spillquantities, duration, and recovery or cleanupassumptions were provided to support thehydrological (surface and subsurface),ecological (land and marine based), humanhealth and safety (immediate and long-term),and air resource (concentrations and deposition)risk assessments. The risk of spills to theseresources was factored into associated socialand economic impacts. Potential iteration andrefinements were made to the spill scenariosfrom consultation with each of the disciplinaryteams and from the review and discussion ofresults.

A.15.2 Calculations Relativeto Oil Spills to SurfaceWater andGroundwater

A.15.2.1 Calculations for thePotential Capture ofCrude Oil

In the event of a pipeline break that releasescrude oil to flowing water, estimates are neededfor several parameters in order to calculate thepotential for recovery of the oil. Parametersinvolved include the location of the leading edgeof the oil in the water at the response time of thecontainment crew (based on time needed for theresponse team to arrive at the containment siteand begin containment activities); the length ofthe oil plume; the percent of oil subject tocapture at the containment location; and thewidth of a spill downstream of the break.

The location of the leading edge of the oil inthe stream or river at the response time wasestimated by multiplying the velocity of the watertimes the response time. The oil is assumed totravel at the water velocity; the water velocity isassumed to be equal to values presented in thecontingency plans for the TAPS ROW.Response times were provided by Folga et al.(2002).

The length of the oil smear in the movingwater was estimated as the product of the watervelocity and the time needed to discharge thedesignated volume of oil from the break.Release volumes and emptying times wereobtained from Folga et al. (2002). For thiscalculation, the oil slick is assumed to movedownstream as a plug, with distinct leading andtrailing edges. The first drop of oil into the waterdefines the leading edge, and the last drop of oildefines its trailing edge. Under actual conditions,the length of the oil slick would extend from theleading edge of the plume to the location of thebreak because of hangup along the route,regions of slower moving water, bends in theriver, turbulent mixing and dispersion, andremobilization of oil from banks and streambeds.

If the flow of oil in the water is conservativelytreated as plug flow (i.e., flow in which theleading and trailing edge of the flow are abrupt),the following equation can be used to estimatethe percent of oil subject to capture at thecontainment site:

,100emptyT

csTresponseTemptyTPC

+−×= (E-1)

where

PC = percent of crude oil subject tocapture at the location of thecontainment site,

Tcs = time for the oil to reach thecontainment site,

Tempty = time to discharge the oil fromthe pipeline break, and

APPENDIX A A-42

Tresponse = time for the response team toreach the containment siteand begin containmentactivities.

The time for the oil to reach the containmentsite is calculated as the distance from the breakto the containment site divided by the velocity ofthe water in the river or stream. Two methodswere used to estimate the time to discharge theoil from the break (Tempty). For a guillotine break(instantaneous release), the time was estimatedas the volume of oil that would be releaseddivided by the throughput value (Folga et al.2002). For prolonged discharges, the emptyingtime was estimated as the volume of oil releaseddivided by the duration time (e.g., 48 hours).Response times were obtained from valuesprovided by Folga et al. (2002).

Because the above equation assumes plug-flow conditions, the result is likely tounderpredict the amount of oil that could becaptured at the containment site. However, moredetailed calculations would require extensivesite-specific hydrological information (e.g., flowrates, stream widths, bed and bank conditions,wind speed and direction, temperature, and icecover) that would only be available at the time ofan actual release.

The final parameter for estimation is thewidth of the slick downstream of the break. Inmany applications, crude oil spills are assumedto spread circularly (Shen et al. 1988). Thisspreading is often represented by the followingequation:

.4/3510 volsA = (E-2)

where

As = area of the spill (m2), and

vol = volume of the spill (m3).

The width of the slick, wslick, is then obtainedfrom the relationship:

.2 sAslickw π×= (E-3)

A.15.2.2 GroundwaterCalculations for aSubsurface Guillotine Break

In an underground guillotine break, crude oilwould be released to the area adjacent to theburied pipe. In regions of stable permafrost, thepipe would release its contents to thaw bulbsformed under normal operations by heat transferfrom warm oil flowing in the pipeline. In areas inwhich permafrost is absent, the release would beto the surrounding soil. As discussed inSection 4.4.4.4.1, a guillotine break in theBrooks or Alaska Ranges would release amaximum of 46,608 bbl of oil to stablepermafrost and thaw bulbs. In the ChugachRange, a maximum release of 38,773 bbl wouldoccur to the backfilled trench. If the trench wasnot sufficiently buried, the pressure from the oilcould force the fluid to the surface of the ground.The presence of ice above the pipeline couldreduce the possibility of this type of event;however, the warm oil could melt the ice andforce its way up to the surface anyway. Impactsfrom this type of spill are addressed inSection 4.4.4.1 for an aboveground guillotinebreak. For an underground guillotine break of thepipeline, the oil is assumed to remainbelowground in either thaw bulbs in permafrostareas or along the pipeline trench in areas wherepermafrost is not present.

In the Brooks and Alaska Ranges, thawbulbs have developed along sections of theburied pipeline. Precise information is notavailable on their size; however, in the vicinity ofPS 3, the thaw bulb is estimated to have adiameter of 60 ft (Keyes 2002). For this analysis,the thaw bulbs are assumed to be circular, with awidth equal to 60 ft. The cross-sectional area, At,of the thaw bulb is then calculated as:

At = πR2, (E-4)

where R is the radius of the thaw bulb. The totalarea is thus about 2,800 ft2.

This entire area is not available fortransporting fluids because of the presence ofsolid material such as sands, gravel, and thepipeline, which has an effective area of about12.6 ft2. For the backfilled trench, the ratio of thevolume of void space present to the total volume(i.e., porosity) is assumed to be 0.3 (Freeze and

A-43 APPENDIX A

Cherry 1979). The area of the thaw bulb that cantransmit a fluid is called the effective area and isdesignated as Ae. This area can be calculatedfrom the total area by multiplying the total area,less the area of the pipeline, by the porosity ofthe fill material, N. That is:

Ae = (At − Apipe)N . (E-5)

For a porosity of 0.3, the effective area of thethaw bulb zone is about 850 ft2.

The maximum volume of oil released for anunderground guillotine break in the Brooks orAlaska Ranges would be 46,994 bbl (about2 million gal). Converting this volume to cubicfeet gives a spill volume of about 263,900 ft3.Dividing the volume of the spill by the effectivearea gives an estimate of the length of oil-filledspace along the pipe. For an effective flow areaof 850 ft2, the oil could occupy a length of about300 ft.

Once in the thaw bulb, the oil would flowdownhill. Because it would be in a porousmaterial, it would have an apparent velocitygiven by the expression:

Φ∇= hK

Vel , (E-6)

where

K = the hydraulic conductivity(measure of the ability of amaterial to transport a fluid) of thefill material in the trench and

Lh = the hydraulic gradient (change inelevation with respect todistance).

For a gravel-like fill, the hydraulicconductivity is about 280 ft/d (Freeze and Cherry1979). Neglecting the initial pressure of the oil inthe pipe, the hydraulic gradient for amountainous region is assumed to be 0.2 (TAPSOwners 2001c). The velocity of the oil in thethaw bulb would, therefore, be about 200 ft/d. Itwould thus take about 1.6 days for the oil totravel 300 ft. Because the pipeline operates at apressure of about 1,180 psi (APSC 2001b), theinitial velocity of the emergent oil will be higherthan that calculated, assuming that the oil wouldflow under the conditions of the natural hydraulic

gradient present. For a pressure of 1,180 psi, theequivalent pressure head (elevation) of the oilcan be found from the expression:

goil

Poilh

ρ= . (E-7)

The pressure head of the oil is thus about3,130 ft for a crude oil density of 0.8699 g/cm3

(Folga et al. 2002). This pressure head wouldincrease the velocity by about 50 to 10,430 ft/d ifa separation distance of 300 ft is used to definethe gradient. The travel time would, therefore, bereduced to about 1 hour. Because the pressurehead of the oil is so high, the spilled oil wouldprobably escape the thaw bulb and discharge atthe ground surface. Once all of the oil in thebroken pipeline segment was released to thethaw bulb, it would continue to movedowngradient until there was a sufficienttopographic change to reduce the hydraulicgradient to zero, or until the oil found a path tothe surface of the ground.

Depending on the time needed to respond tothe spill, more than 300 ft of thaw bulb would becontaminated by the spilled oil. Because thespilled oil in the thaw bulb would still be underpressure, care would have to taken in excavatingdown to the pipeline.

In addition to contaminating the water inthaw bulbs along the TAPS, oil released from anunderground guillotine break could melt thesurrounding permafrost. The melting wouldoccur because the crude oil from the pipelinewould be warmer than the ice.

It is assumed that initially, the oil in thepipeline in the vicinity of the spill would be 110EF(43EC) and the temperature of the permafrostwould be 23EF (-5EC). It is assumed that atequilibrium, the oil would cool to 32EF (0EC), andthe permafrost would convert to water at 32EF(0EC). The change in energy in the oil wouldwarm the permafrost to its melting point and thenmelt it. Sufficient ice is assumed to be present toprevent the melt water from increasing intemperature to a value greater than 32EF (0EC).This thermodynamic process can be representedby the following equation derived from phasechange information presented in Sears (1964):

APPENDIX A A-44

Cpoil∆ ToilMoil = Micehf + Cpice∆TiceMice , (E-8)

where

Cpoil = specific heat capacity of oil(j/kg/K),

Cpice = specific heat capacity of ice(j/kg/K),

hf = latent heat of fusion (ice towater) (j/kg),

Moil = mass of oil spilled (kg),

Mice = mass of ice melted (kg),

)Toil = temperature change of the oil (K),and

)Tice = temperature change for the ice(K).

Equation 5 can be solved for the mass of icethat could be melted by the warm oil:

iceTiceCpfhoilMoilToilCp

iceM∆+

∆= . (E-9)

The mass of oil spilled is calculated as itsdensity (0.8699 g/cm3 times the spill volume(46,994 bbl). The specific heat capacity of thecrude oil was assumed to be constant and equalto about 2,100 j/kg/K (mid-continent crude withan API gravity of 30E [Bradley 1992]). This valueis consistent with the finding that the specificheat capacity of crude oil is about one-half thatof water (Davies et al. 1999), which is about4,190 j/kg/K (Weast 1968). Other values neededto evaluate Equation E-9 are listed in Table A-5.

TABLE A-5 Physical Constantsfor Ice-Melt Calculation

Parameter Value

Hf 335,000 j/kg (Weast 1969)

)Tice 5°C

)Toil 43°C

Cpwater 4,184 j/kg/K (Weast 1969)

The maximum volume of ice that could bemelted according to Equation E-9 for the giveninput parameters is about 1.7 × 106 kg. For anice density of 917 kg/m3 (Davis 2001), about65,300 ft3 (1,850 m3) of ice could melt. If icemelted from around the thaw bulb in a concentriccircle, the radius of the melted zone can befound from the following relation:

π(r 2 − r02)L = Volice , (E-10)

where

L = the length of the region thatwould fill with oil,

r0 = the radius of thaw bulb (30 ft),and

Volice = the volume of ice melted.

Solving for the radius of the melt zone gives:

20π

rLiceVol

r += . (E-11)

For a volume of ice of 65,000 ft3, the radius ofthe circle melted by the warm oil would be about31 ft. The new diameter of the thaw bulb wouldbe about 62 ft.

In the Chugach Range, an undergroundguillotine break would release crude oil to thesoil. In that region, the pipeline trench isassumed to have a width of 8 ft and a depth of12 ft, with about 4 ft of fill material on top of thegravel pack. The total cross-sectional area of thegravel pack and pipe is assumed to be 64 ft2.Subtracting the area of the pipe and multiplyingby an assumed porosity of 0.3 gives an effectivearea of about 15 ft2. For a release of 38,773 bbl(about 220,000 ft3), the oil could fill an annulusof about 2.7 mi.

A.15.3 Fire Analysis of SpillEvents

The spills analysis identified six spillscenarios involving fires that could be defined ascredible events (frequency of occurrence greaterthan once in a million years). The first two crudeoil fire events considered are those occurring atfixed pipeline facilities. Each of these events

A-45 APPENDIX A

____________________________

4 As multicomponent mixtures do not evaporate at uniform rates, fires involving fuel blends, such as crude oil, donot burn at uniform rates. At the beginning of the fire the burning rate is characteristic of the more volatile lowerboiling point components (e.g., butane burns at around 0.8 kg/m2-s), while near the end of the fire the higherboiling point components burn at a slower rate, typically around 0.04 kg/m2-s (Mudan 1994). Because the light-ends burn off so rapidly, the average burn rate is closer to slower and, therefore, longer burning heavy-ends(higher molecular weight and higher boiling point components, such as acetone).

involves very large crude oil pool fires from anaircraft impact: one in the secondarycontainment dike at the Valdez Marine TerminalEast Tank Farm (identified as Scenario 10 inSection 4.4.1), and one resulting from a pipelineguillotine break near Fairbanks (identified asScenario 19b Section 4.4.1). The last four firespill scenarios are vehicle transportationaccidents. Three of the scenarios involverollovers of fuel tanker trucks carrying liquidturbine fuel during shipments between(1) Williams North Pole Refinery to PS 7 and 3,(2) Williams North Pole Refinery to PS 9, and(3) PetroStar Refinery in Valdez to PS 12. Thesixth transportation spill scenario involving a fireis a fuel truck shipment carrying arctic gradediesel from the Williams North Pole Refinery toDeadhorse. Because the transportation spillscenarios involved much smaller spill quantitiescompared with the Valdez Marine Terminal andpipeline fire scenarios, quantitative analysis ofthese events was not performed. The associatedconsequences and risk of truck accidentsinvolving flammable and/or explosive materialscan be found in the DOT National TransportationRisk Assessment (Brown et. al. 2000a).

To estimate fire impacts, simulations wereperformed with two models: the Fire DynamicsSimulator (FDS) and FIREPLUME. The near-field (distances less than 1 km from the dike fire)air quality impacts from this dike fire wereassessed with the FDS model for locations nearthe dike and pipeline, and at distances from thefire where workers or nearby residences may beexposed. FIREPLUME was used to estimatesoot and other combustion product impacts froma few kilometers to 50 km downwind of the dikefire. Considering the uncertainty in any model�spredictions, a decision was made to err on theconservative side by using the results from themodel producing the largest concentrationestimates in the downwind range from 3 to10 km.

Earlier versions of FDS have been applied inestimating particulate concentrations from in-situburning of crude oil in Alaska as far out as 4 to6 km (McGrattan et al. 1995). The strongest

limitation of the FIREPLUME analysis for theValdez cases is the neglect of terrainconsiderations since FIREPLUME is based on aflat terrain representation of the atmosphericboundary layer. The mountains surroundingValdez may lead to higher ground-level impactsthan predicted by the model because of the largeamount of vertical mixing that can occur on thelee sides of mountain ranges.

The FDS (version 2.2) model was used toestimate key fire buoyancy parameters(temperature, vertical velocity, and plumedensity) and near-field soot and othercombustion product impacts. The model iscapable of simulating fire-induced flows or windfields that influence smoke groundconcentrations close to or within a fewkilometers of the fire. A detailed description ofthe model can be found in McGrattan et. al.(2001). The fire combustion product airemissions were estimated using emissionfactors derived from the Newfoundland offshoreburn experiment as reported in McGrattan et. al.(1997) and with an average constant burn rate of0.051 kg/m2-s for North Slope crude oil(McGrattan et. al. 1997).4 Emission factors,which express pollutant mass release per unitmass of fuel consumed, were available forsmoke/soot particles in various size fractionsand for six gaseous fire combustion products(CO, SO2, NOx, VOCs, PAH, and CO2).Laboratory and field experiments involvingvarious crude oil pool fire sizes show that largerfires tend to produce larger soot yields (rangingfrom around 5 to 15%). The quantity of sootgenerated in pool fires is by far the largestquantity on a mass basis of any of the majorpollutants emitted from such fires. On the basisof smoke production data collected in largecrude oil mesoscale burn experiments, a sootyield of 13.7% was assumed for the ValdezMarine Terminal and pipeline scenarios(Notarianni et. al. 1993). A soot emission factorcan be computed by taking the ratio of the massof soot released in the fire (soot yield × mass ofoil burned) to the mass of oil burned. The sootemission factor with a 13.7% yield is calculatedto be 137 g/kg (estimated soot generation

APPENDIX A A-46

mass/mass of crude oil burned). Data on smokeparticle size distributions reported by McGrattanet al. (1997) show that 87% of the particulatemass from burns of several crude oil types,including North Slope and Cook Inlet crudes,was represented by particles less than or equalto 10 µg in diameter. These data assume a 13%soot emission factor.

The buoyancy parameters generated withthe FDS model were used as input to theFIREPLUME model (Brown et. al. 2000b). TheFIREPLUME model predicts the ground-levelconcentration field resulting from chemicals orcombustion products emitted from or within(1) fires that generate hot continuous plumessuch as the oil fires considered in this analysis;(2) instantaneously discharged thermal orexplosive discharges; or (3) smoldering ordecaying fires, including the nominal case ofpassive or neutrally buoyant releases, whichserve as a limiting case for a smoldering fire.There are four classes of fires, categorizedaccording to the kind of material that is burning.Both of the TAPS pool fire scenarios wouldgenerate very hot plumes typical of Class B fires,which involve flammable and combustible liquidsthat are best extinguished by foam, CO2, or drychemicals. All petroleum fires, including firesinvolving crude oil, are considered Class B fires,which can be very hot and do not exhibit asmoldering combustion phase.

The FIREPLUME model consists of twocomponents. The first is a single particleLagrangian dispersion model that estimatesvertical dispersion of both buoyant andnonbuoyant releases in the atmosphericboundary layer. The second component is a puffdispersion model that translates the verticaldispersion estimates to ground-levelconcentrations taking into account horizontaldispersion and transient source emissioncharacteristics. The calculation is broken up inthis manner to reduce computational time. Takentogether, these components provide time varyingconcentration fields resulting from releases inwhich both the buoyancy and chemical releaserate vary with time. The framework for treatingsource buoyancy closely follows from the so-called Brigg�s two-thirds law (see Briggs 1984),which is applicable in cases in which thebuoyant source has low initial momentum. Fires

clearly fall into this category (Weil 1982). Theplume rise relationships incorporated intoFIREPLUME provide a mean vertical velocity forthe individual particles. The final or limiting riseof the particles is established using publishedrelationships for a variety of atmosphericconditions that incorporate natural statisticalvariability in plume rise observed in experimentalstudies. Using this framework, the verticaldispersion from a variety of buoyant releasescenarios can be evaluated; from intenselybuoyant sources typical for large oil fires to verylow buoyancy sources, such as in the residualstages of smoldering biomass. Additional detailson the underlying basis of FIREPLUME arecontained in Brown et al. (1997).

Ground-level concentration-emission ratios(χ/Q, commonly referred to as Chi over Qs) werecomputed with FIREPLUME at 500-m intervalswith downwind distances ranging from 3 to50 km. Air pollutant concentrations at thesedistances were derived by multiplying theseratios by the computed fire combustion productpollutant emission rates. The fire emission rateswere calculated by multiplying the North Slopecrude oil fire emission factors by the assumedburn rate flux (i.e., rate of crude oil burn per unitarea) and the estimated fire pool area.

A variety of meteorological conditions wereconsidered in the analysis of fires at Valdez andFairbanks. However, because of the large size ofthe hot fires in each of these locations, verybuoyant high-rising plumes would be expectedeither to fully penetrate or become partiallytrapped below the mixing layer. The largestdownwind concentrations of soot and smokewould be expected to occur under unstableatmospheric conditions. However, thoseconditions would also need to be accompaniedby sufficiently inversion layer heights to preventpenetration of the plume and loss of sootparticles above the boundary layer. Completepenetration of this layer would result in pollutanttransport above the boundary layer over largedownwind distances. In considering daytimeunstable conditions (as represented withPasquill Gifford stability Classes A, B, or C), theplume fully penetrates the temperatureinversion, marking the top of the atmosphericboundary layer, and becomes confined abovethat level. The conditions necessary for a portion

A-47 APPENDIX A

of the plume to become trapped within theboundary layer include both a wind speed inexcess of 7 m/s at 10 m and a strong elevatedinversion layer. If these conditions are met, it isestimated that significant ground-level impactswould be possible. Even for these cases,though, most of the plume rises above theinversion and is, therefore, prevented fromreentering the mixing layer and thereby throughvertical advection and dispersion make itpossible for soot impacts at ground level. Duringthe daytime cases studied for Valdez andFairbanks, it is estimated that 90 and 80%,respectively, of the material penetrates theinversion and is therefore trapped above. Theremaining quantity cools within the region of theinversion and then disperses back down toground level after a few hours. The occurrenceof plume penetration and the percentages of theplume trapped above the boundary layer areconservatively estimated based on formulationpresented in Weil (1988).

The same general considerations apply forstable conditions; namely, ground-level impactsdo not occur when wind speed is less than about7 m/s. The mechanism here is a little different,however, in that the plume rises to a height atwhich the atmosphere is very stably stratified,thus preventing the plume from dispersing backdown to ground level. Depending on the low-level stability of the atmosphere and the lapserate, this final plume height can be as low as300 m or as high as 3,000 m. Cases in which theplume rises to a height exceeding the boundarylayer height (which for stable conditions is theheight at which sheer-induced turbulence falls tonegligible value) led to no ground-level impactsin our analysis. In practice, however, thesecases may result in some ground-level impactswhen strongly stable conditions (say F stability)are followed by fairly rapid warming, thuscreating a classic fumigation condition. This is afairly unlikely scenario in Alaska, although,because of the slower warming caused by thegenerally low solar elevation angles coupledwith the very gradual increase of solar elevationangle with time. Nighttime cases that lead toground-level impacts are characteristic of Dstability as is the case for the daytime cases,due to the need for high wind speeds. Boundarylayer heights chosen for these cases (between700 and 1,500 m) are at the upper range of

possible values and were selected to capture asmuch of the plume within the boundary asreasonably possible given the wind speed.

A.16 CumulativeAssessment

A.16.1 Introduction

Cumulative effects would result from theincremental impact of the proposed action whenadded to other past, present, and reasonablyforeseeable future actions, regardless of whatgovernment agency or private entity undertakessuch actions. Cumulative effects can result fromindividually minor impacts that when viewedcollectively over space and time can producesignificant impacts (40 CFR 1508.7).

The analysis of cumulative impactspresented in Section 4.7 focuses on human andnatural resources or environmental receptorsthat can be affected by the incremental impactsof the proposed action and alternatives.Generally, the geographic area for a cumulativeimpact analysis is defined by the specificresource or receptor of concern and the spatialextent of the interacting (cumulative) impactgenerators. The temporal extent of thecumulative analysis extends from the pasthistory of impacts to each receptor through theanticipated life of the project, including additionaltime necessary for decommissioning andrestoration, if appropriate.

Cumulative analyses, by definition,incorporate an extensive range of potentialstressors and thus provide decision makers andthe public with an overview of the condition(past, present, future) of a receptor or resourcewithin the region of interest. This broaderoverview of the set of potential impacts to aresource allows decision makers to place thedirect and indirect impacts of the proposedaction within the context of other potentialstressors.

As a starting point, the cumulative analysisuses the direct and indirect effects of theproposed action and alternatives developedduring the scoping phase of this DEIS. For the

APPENDIX A A-48

proposed action (renew the Federal Grant for theTAPS ROW) and the less-than-30-year renewalalternative, a number of impacting factors wouldresult from the continued operation andmaintenance of TAPS facilities. The impactingfactors and the resultant direct and indirectimpacts of the proposed action on receptors andresources are developed in Chapter 4 of thisDEIS. The no-action alternative also has a set ofimpacting factors with another set of direct andindirect impacts. Examples of impacting factorsinclude accidental spills of oil, operation ofmaterial and disposal sites, operation of supportfacilities (e.g., airports, access roads, workcamps), repair and maintenance activities,pipeline surveillance activities, and thetransportation of goods and services for pipelineoperation or pipeline disassembly, removal, andROW restoration. The impacting factorsassociated with other reasonably foreseeableactions are presented in Section 4.7.5. The fullset of impacting factors is found in thedescription of alternatives presented inChapter 2 and the impact analysis presented inChapter 4.

Direct effects would be the initial impactscaused by the proposed action, less-than-30-year renewal alternative, and no-actionalternative and would occur at the same timeand place as those actions. Indirect effectswould also be caused by the proposed actionand the alternatives, but generally would besubsequent to or caused by the initial directimpacts. Indirect effects may occur at a latertime or in another location than direct effects.For example, changes in land use, populationdensity, or economic conditions that are a directresult of the proposed action or no-actionalternative could then impact air or water quality,ecosystem function, or the introduction ofinvasive species. In addition, indirect effects canresult in positive or negative feedback systemsthat further exacerbate positive or negativechanges in environmental quality.

The cumulative analysis for the proposedrenewal of the TAPS ROW encompasses energydevelopment and transportation activities thatbegin on the North Slope and end with transportof oil in tankers departing from the ValdezMarine Terminal at Prince William Sound. Theprimary energy activities include oil exploration,

oil field development, the transportation of oil inpipeline systems located within developed oilfields (including oil fields located in offshoreareas), the transportation of oil in the TAPS,operations at the Valdez Marine Terminal, andthe transport of oil in tankers. Energy activities(development, extraction, and transportation)constitute a primary set of potential impactingfactors for the cumulative analysis of theproposed action and alternatives. Additionalactivities include oil refining, potential naturalgas development and transportation, humanhabitation and development, other transportation(roads, rails), legislative actions related to landuse, land management, natural resource use,and petroleum spills.

A.16.2 General Approach

The general approach for the cumulativeassessment follows the principles outlined by theCEQ (1997) and the guidance developed by theEPA (1999b) for independent reviewers ofenvironmental impact statements. Thecumulative assessment conducted for therenewal of the Federal Grant of ROW for theTAPS incorporates the following basicspecifications:

• Individual receptors described in Chapter 4become the end points or units of analysisfor the cumulative assessment;

• Direct and indirect effects described inChapter 4 form the basis for the impactingfactors used in the cumulative analysis;

• Impacting factors are derived from a set ofpast, present and reasonably foreseeablefuture actions or activities; and

• Each individual receptor and the set of past,present, and reasonably foreseeable futureactions or activities that could impact thereceptor define the temporal and spatialboundaries of the cumulative analysis.

The evaluation of significance incorporatesdata, analysis, and results on probability ofimpact, consequences of impact, spatial andtemporal extent of the impacting factor andreceptor, recovery potential, and mitigationactions. Some of the information can be

A-49 APPENDIX A

quantified, such as the spatial extent of theimpacting factors, while other analyses andresults could require estimates based onsummaries of published literature or scientificallybased first principles developed within eachdiscipline. First principle can also be defined asprofessional judgment; the judgment, however,is based on accepted theories, experiments, andanalytical constructs developed under standardscientific methods for each scientific discipline.

A.16.3 Methodological Steps

The methodology of cumulative impactassessment follows the steps presented below.The cumulative analysis uses results producedin Chapter 4 of the draft DEIS and the set ofpast, present, and reasonably foreseeableactivities developed specifically for thecumulative analysis. The methodology isconsistent with guidance developed by the CEQand the EPA. The procedure used is outlinedbelow:

• Step 1, Define Alternatives for theDEIS: The alternatives considered in theTAPS DEIS include (1) proposed action(renew the grant of ROW for up to 30 years)(2) less-than-30-year renewal (renew thegrant of ROW for a period less than 30years), and (3) no action (do not renew thegrant of ROW). Each alternative is describedin Chapter 2. On the basis of the impactingfactors associated with each alternative, thedirect and indirect effects of the alternativesare developed in Chapter 4.

• Step 2, Define the Region ofInfluence: The cumulative analysisdelineates TAPS oil production and deliverycomponents into three major geographiccategories: (1) North Slope (including off-shore) exploration, development, andproduction activities; (2) the TAPS ROW andassociated facilities; and (3) thetransportation of oil in tankers from theValdez Marine Terminal, especiallytransportation activities in Prince WilliamSound. While these geographic areas for thecumulative analysis are not used toconstrain individual analyses, the spatialdelineation along three major components ofoil production and distribution activities

provides a useful format for organizing thedocument and presenting results.

• Step 3, Define Past, Present, andReasonably Foreseeable Actions:The set of past, present, and reasonablyforeseeable actions is developed fromconsultations with other governmentagencies, elected officials, Alaska Nativeorganizations and nongovernmentalorganizations; through public scoping; and inconsultation with knowledgeable privateentities, such as the TAPS ownercompanies. The past, present, andreasonably foreseeable actions includeactions directly related to the proposedaction. These actions are dependent onrenewal of the grant of ROW and arestrongly tied to future pipeline operations. Inaddition, the past, present, and reasonablyforeseeable actions include indirect activitiesthat were dependent on past TAPS actions,such as construction or past pipelineoperations. Finally, past, present, andreasonably foreseeable actions includeactivities that are unrelated to the renewal ofthe ROW or TAPS present and futureoperations, but which could have impacts onreceptors identified in Chapter 4 and that arelocated in the TAPS region of influence. Theactivities considered by area are outlined inTable A-6.

• Step 4, Develop the List ofReceptors: The list of receptors (endpoints) for the cumulative assessment wasderived from the receptors developed inChapter 4. If possible, the receptors areplaced or binned into a smaller number ofcategories. For example, habitat conditioncould be described in a way that a number ofground nesting birds can be examinedtogether, rather than a species by speciesanalysis.

• Step 5, Incorporate the Direct andIndirect Effects Developed inChapter 4: The direct and indirect effectsare taken from the direct and indirect effectsdeveloped in Chapter 4. Direct effects arecaused by implementing each alternativeand occur at the same time and place.Indirect effects are caused by thealternative, but are later in time or farther

APPENDIX A A-50

TABLE A-6 Past, Present, and Reasonably Forseeable Future Actions

Category Past Actions Present ActionsReasonably Foreseeable

Actions

Beaufort Sea

Oil and gas exploration, development and production

$ Oil fields $ Oil fields $ Oil fields

Oil and gas transportation

$ Carrier pipelines$ Fuel transfer from barges

and other vessels


and other vessels


and other vessels

Human habitation and development

$ Towns and villages $ Towns and villages $ Towns and villages

Legislative actions related to land use

$ Alaska Native ClaimsSettlement Act

$ Alaska National InterestLands Conservation Act

$ Federal Coastal ZoneManagement Act

$ Alaska Coastal ZoneManagement Act









Land management activities/plans

$ Barrier islands $ Barrier islands $ Barrier islands

Natural resource use $ Subsistence$ Recreational

development$ Commercial development

$ Subsistence$ Recreational




North Slope

Oil and gas exploration, development, and production

$ Oil fields$ Oil refineries$ Gas processing plants$ Seawater treatment

plants$ Power plants





Oil field support facilities

$ Infrastructure atDeadhorse

$ Gravel sources$ Dalton Highway, access

roads



roads



roads

A-51 APPENDIX A

TABLE A-6 (Cont.)


Actions


$ Carrier pipelines$ TAPS$ Natural gas pipeline$ Pipeline System from

TAPS to Williams andPetro-Star Refineries(North Pole)

$ Carrier Pipelines$ TAPS$ Natural gas pipeline$ Pipeline System from


$ Carrier Pipelines$ TAPS$ Natural gas pipeline$ Pipeline System from



$ Towns and villages $ Towns and villages $ Towns and villages

Transportation (general)

$ Haul Road $ Haul Road $ Haul Road















$ National parks,preserves, andmonuments









Interior Alaska

Oil and gas exploration, development, and production

$ None $ Exploration (Nenana,Copper River, andSusitna Basins)

$ Exploration (Nenana,Copper River, andSusitna Basins)

Oil field support facilities

$ Gravel sources$ Dalton Highway




$ TAPS$ Natural gas pipeline



Oil refining $ William Alaska Petroleum(North Pole)

$ Petro Star (North Pole)

$ William Alaska Petroleum(North Pole)


$ William Alaska Petroleum(North Pole)


APPENDIX A A-52

TABLE A-6 (Cont.)


Actions

Oil storage $ Williams Terminal(Fairbanks InternationalAirport)

$ Williams Terminal(Fairbanks InternationalAirport)

$ Williams Terminal(Fairbanks InternationalAirport)


$ Cities, towns, andvillages

$ Industry related


$ Industry related


$ Industry related


$ Highways$ Railroads$ Public air strips












$ Alaska Department ofNatural Resources

$ Military



$ Military



$ Military







Prince WilliamSound

Oil refining facilities $ Oil Refineries (Valdez) $ Oil Refineries (Valdez) $ Oil Refineries (Valdez)


$ TAPS$ Pipeline System from

TAPS to Tesoro andPetro-Star Refineries

$ Tanker loading andtransport







Oil storage $ Valdez Marine Terminal $ Valdez Marine Terminal $ Valdez Marine Terminal



$ Industry related


$ Industry related


$ Industry related

A-53 APPENDIX A

TABLE A-6 (Cont.)


Actions


$ Highways$ Railroads$ Public air strips$ Marine facilities



















$ Military



$ Military



$ Military







removed in distance. Indirect effects mayinclude growth-inducing effects and othereffects related to induced changes in thepattern of land use, population density orgrowth rate, and related effects on air andwater and natural system function(e.g., ecosystem function).

• Step 6, Determine the ImpactingFactors of Each Cumulative Actionor Activity: For each action developedunder Step 3, a description (qualitative orquantitative) of the impacting factors isdeveloped. The impacting factors arecategorized so that similar impacting factorsfrom different activities are considered as asingle cumulative impacting factor. However,the spatial extent of the single impactingfactor incorporates all the cumulative actionsthat contribute to the impacting factor.Intensity is defined in terms of some aspect

of quantity (e.g., volume, land or water areaaffected, toxicity level, persistence) for theimpacting factor.

• Step 7, Evaluate CumulativeImpacts on the Receptors: For eachreceptor or category of receptors, anevaluation of the cumulative impactsaddresses the following:

− The collective magnitude, importance,and significance of all actions;

− The incremental contribution of theproposed action to the magnitude,importance, and significance of thecumulative impact; and

− The magnitude, importance, andsignificance of the impact that could

APPENDIX A A-54

occur under the alternatives, including noaction.

The cumulative assessment uses thefollowing set of criteria to judge the magnitude,importance, and significance of an impact on areceptor:

− Likelihood of the impact,

− Consequences of the impact,

− Geographic or spatial extent of thepotential impacting factor,

− Geographic or spatial extent of thereceptor,

− Temporal extent of the impacting factor,

− Regulatory considerations (e.g.,threatened and endangered species,marine mammals, cultural resources),

− Potential for recovery of the receptor afterremoval of the impacting factor, and

− Potential for effective mitigation.

• Step 8, Presentation of theCumulative Impacts in the DEIS:The cumulative impacts are presented intext form incorporating the informationdeveloped in Step 7. A summary table ispresented at the end of the textualdiscussion to provide a condensed versionof the bottom-line cumulative impacts.

A.17 References forAppendix A

ADF&G (Alaska Department of Fish and Game),1998, Catalog of Waters Important for Spawning,Rearing, or Migration of Anadromous Fishes,Vols. 1−6, Habitat Division, Anchorage, Alaska,revised periodically.

ADNR (Alaska Department of NaturalResources), 1991, Tanana Basin Area Plan forState Lands, Anchorage, Alaska.

ADNR, 2001, State of Alaska TAPS LeaseRenewal Project Map of Existing Leases andPermits, Anchorage, Alaska.

ADNR and ADF&G (Alaska Department of Fishand Game), 1986, Copper River Basin Area Planfor State Lands, Anchorage, Alaska, Dec.

ADNR and ADF&G, 1988, Prince William SoundArea Plan for State Lands, Anchorage, Alaska.

APSC (Alyeska Pipeline Service Company),1993, Environmental Atlas of the Trans AlaskaPipeline System, Anchorage, Alaska.

APSC, 1998a, Trans Alaska Pipeline SystemEnvironmental Protection Manual, Section 8,EN 43-1, 6th Ed., Anchorage, Alaska.

APSC, 1998b, Best Management Practices Plan,Ballast Water Treatment, Alyeska MarineTerminal, MP 69-1, 2nd Ed., Rev. 03,Anchorage, Alaska.

APSC, 2000, Trans Alaska PipelineEnvironmental Protection Manual, WasteManagement, EN-43-2, Anchorage, Alaska.

APSC, 2001a, Trans-Alaska Pipeline SystemPipeline Oil Discharge Prevention andContingency Plan General Provisions,CP-35-1 GP, TBD, Anchorage, Alaska.

APSC, 2001b, Trans Alaska Pipeline SystemFacts, Anchorage, Alaska, June.

APSC, 2001c, Guide for Packaging andTransporting Hazardous Materials/DangerousGoods by Highway and by Aircraft, H2-124,3rd Ed., Rev. 02.

Aus, W.T., et al., 2001, TAPS ValveMaintenance Plan, Final Report, 10 PipelineValves with Leak-through Risk Assessment,Alyeska Pipeline Service Company, Anchorage,Alaska.

Berman, et al., 1986, ISER MAP AlaskaEconomic Model: State Model Documentation,A86.1, University of Alaska-Anchorage, Instituteof Social and Economic Research, June.

A-55 APPENDIX A

BLM (U.S. Bureau of Land Management), 1980,Management Framework Plan for theSouthcentral Planning Area, Anchorage DistrictOffice, Anchorage, Alaska.

BLM, 1983a, River Management Plan for theDelta National Wild and Scenic River,Anchorage District, Alaska. Available athttp://www.glennallen.ak.blm.gov/delta/index.html.

BLM, 1983b, River Management Plan for theGulkana National Wild River, Anchorage District,Alaska. Available at http://www.glennallen.ak.blm.gov/gulkana/ index.html.

BLM, 1989, Utility Corridor Proposed ResourceManagement Plan and Final EnvironmentalImpact Statement, Arctic District Office,Fairbanks, Alaska.

BLM, 2001, Identification of Tribes forConsultation for TAPS Renewal, Anchorage,Alaska.

BLM, 2002, Biological Evaluation of the Effectsof the Right-of-Way Renewal for the Trans-Alaska Pipeline System on Threatened andEndangered Species and Designated CriticalHabitat, Draft, May.

BLM and USARAK (U.S. Army AlaskaCommand), 1994, Fort Greely ProposedResource Management Plan FinalEnvironmental Impact Statement.

Bradley, H.B., 1992, Petroleum EngineeringHandbook, Society of Petroleum Engineers,Richardson, Texas.

Briggs, G.A., 1984, �Plume Rise and BuoyancyEffects,� pp. 327−361 in Atmospheric Scienceand Power Production, DOE/TC-27601(DE84005177), U.S. Department of Energy,Technical Information Center, Office of Scientificand Technical Information, Washington, D.C.

Brown, D.F., et al., 1997, FIREPLUME Model forPlume Dispersion from Fires: Application toUranium Hexafluoride Cyclinder Fires,ANL/EADTM-69, Argonne National Laboratory,Argonne, Ill., June.

Brown, D.F., et al., 2000a, A NationalTransportation Risk Assessment for HazardousMaterials in Transportation, ANL/DIS-01-1,Argonne National Laboratory, Argonne, Ill., Dec.

Brown, D.F., et al., 2000b, �The FIREPLUMEand SMOKE Modes: Tools for EventualApplications to Wildland Fires and PrescribedBurn,� in Vol. II of Crossing the Millennium:Conference and Workshop, Integrating SpatialTechnologies and Ecological Principals for aNew Age in Fire Management, Proceedings ofthe Joint Fire Science Conference andWorkshop, University of Idaho, Moscow, Idaho.

Capstone (Capstone Engineering Services, Inc.),2001, Risk Assessment, Trans Alaska PipelineSystem, Final Report, prepared for AlyeskaPipeline Service Company, Nov.

CEQ (Council on Environmental Quality), 1997,Environmental Justice Guidance under theNational Environmental Policy Act, ExecutiveOffice of the President, Washington D.C., Dec.

City of Valdez, 2000, Valdez ComprehensivePlan.

Dalton Highway (Dalton Highway Advisory andPlanning Board), 1998, Dalton Highway MasterPlan, March.

Davies, L., et al., 1999, Estimation of OilThickness, A Report Produced for the Maritimeand Coastguard Agency, AEAT-5279, Issue 1,AEA Technology Environment, NationalEnvironmental Technology Centre, Oxfordshire,United Kingdom, Nov.

Davis, N., 2001, Permafrost, a Guide to FrozenGround in Transition, University of Alaska Press,Fairbanks, Alaska.

Det Norske Veritas et al., 1996, Prince WilliamSound, Alaska, Risk Assessment Study, FinalReport, prepared for the Prince William SoundAssessment Steering Committee.

DOE (U.S. Department of Energy), 1990, DraftSupplemental Environmental Impact Statementfor the Superconducting Super Collider,DOE/EIS-0138DS, Washington, D.C., Aug.

APPENDIX A A-56

DOE, 2001, Future Oil Production for the NorthSlope, DOE/EIA-0627, Energy InformationAdministration, Washington, D.C., May.

Emerald Consulting Group, Inc., 2001, ValdezMarine Terminal Oil Spill Risk Assessment,Anchorage, Alaska.

EPA (U.S. Environmental Protection Agency),1989, Risk Assessment Guidance for Superfund,Vol. 1, Human Health Evaluation Manual(Part A), EPA/540, Office of Emergency andRemedial Response, Washington, D.C., Dec.

EPA, 1995, User�s Guide for the IndustrialSource Complex (ISC3) Dispersion Models,Vols. 1 and 2, EPA-454/B-95-003a and b,version 02035, Office of Air Quality Planning andStandards, Research Triangle Park, N.C., Sept.

EPA, 1999a, Risk Management ProgramGuidance for Offsite Consequence Analysis,EPA 550-B-99-009, Office of Solid Waste andEmergency Response, Washington, D.C., April.

EPA, 1999b, Consideration of CumulativeImpacts in EPA Review of NEPA Documents,Office of Federal Activities, Washington, D.C.Available at www.epa.gov/oeca/ofa/cumula.html.

EPA, 2001, Integrated Risk Information System,database from Office of Research andDevelopment. Available at http://www.epa.gov/epahome/whatsnew.htm.

EPA et al., 1999, ALOHA User�s Manual,prepared by EPA, National Oceanic andAtmospheric Administration, ChemicalEmergency Preparedness and PreventionOffice, and Hazardous Materials ResponseDivision. Available at www.nwn.noaa.gov/sites/hazmat/cameo/aloha.html. Accessed April 2,2002.

Fairbanks North Star Borough, 1999, FairbanksNorth Star Borough Comprehensive Plan,Department of Community Planning, adoptedMarch 1984, Rev. April 1999, Fairbanks, Alaska.

Fletcher, J.L., and R.G. Busnel, 1978, Effects ofNoise on Wildlife, Academic Press, New York,N.Y.

Folga, S., et al., 2002, Spill ScenariosConsidered in the Trans Alaska Pipeline SystemRight-of-Way Renewal Environmental ImpactStatement, letter report to J. Krummel, ArgonneNational Laboratory, Argonne, Ill., May.

Freeze, R.A., and J.A. Cherry, 1979,Groundwater, Prentice-Hall, Inc., EnglewoodCliffs, N.J.

Goldsmith, O.S., 1997, Structural Analysis of theAlaskan Economy: A Perspective from 1997,University of Alaska-Anchorage, Institute ofSocial and Economic Research.

ISER (Institute of Social and EconomicResearch), 1985, ISER MAP Alaska EconomicModeling System Documentation, University ofAlaska-Anchorage.

IT Alaska, Inc., 2001, Oil Spill Air EmissionsModeling (COA-3) Valdez Marine Terminal,Valdez, Alaska, prepared for Alyeska PipelineService Company, Ship Escort and ResponseVessel System (SERVS), Anchorage, Alaska,Nov.

Keyes, D., 2002, personal communication fromKeyes (Joint Pipeline Office, Anchorage Alaska)to D. Tomasko (Argonne National Laboratory),Feb. 14.

Mach, J.L., et al., 2000, Estimation of Oil SpillRisk from Alaska North Slope, Trans-AlaskaPipeline, and Arctic Canada Oil Spill Data Sets,Final Report, Study MMS 2000-007, prepared byHart Crowser, Inc., for U.S. MineralsManagement Service, Alaska Outer ContinentalShelf Region, Anchorage, Alaska, April.

Malvick, M.J., and B. Weber, 1997, Trans-AlaskaPipeline System Primary Block Valve RiskAssessment, Alyeska Pipeline ServiceCompany, Anchorage, Alaska.

McGrattan, K.B., et al., 1995, Smoke PlumeTrajectory from In Situ Burning of Crude Oil inAlaska: Field Experiments, NISTIR 5764,National Institute of Standards and Technology,Gaithersburg, Md., Nov.

A-57 APPENDIX A

McGrattan, K.B., et al., 1997, Smoke PlumeTrajectory from In Situ Burning of Crude Oil inAlaska: Field Experiments and Modeling ofComplex Terrain, NISTIR 5958, NationalInstitute of Standards and Technology,Gaithersburg, Md., Jan.

McGratten, K.B., et al., 2001, Fire DynamicsSimulator (Version 2) Technical ReferenceGuide, NISTIR 6783, National Institute ofStandards and Technology, Gaithersburg, Md.,Nov.

Mudan K.S., 1994, �Thermal Radiation Hazardsfrom Hydrocarbon Pool Fires,� Progress inEnergy Combustion Science (10):59−80.

Mylius, R., 2002 e-mail from Mylius (AlaskaDepartment of Natural Resources, ResourceAssessment and Development Section,Anchorage, Alaska) to C. Adornatto (ArgonneNational Laboratory), Jan. 16.

National Research Council, 1998, Double-HullTanker Legislation, an Assessment of the OilPollution Act of 1990, Commission onEngineering and Technical Systems, MarineBoard, National Academy Press, Washington,D.C.

NOAA (National Oceanic and AtmosphericAdministration), 2001a, Oil Chemistry and OilTypes. Available at http://www.darcnw.noaa.gov/iad_ap-c.pdf. Accessed Dec. 12, 2001.

NOAA, 2001b, Fact Sheet: Alaska North SlopeCrude Blends. Available at http://response.restoration.noaa.gov/oilaids/crudes.pdf.Accessed Dec. 12, 2001.

North Slope Borough, 1983, North SlopeBorough Comprehensive Plan, Barrow, Alaska,Jan. 1.

Notarianni, K.A., et al., 1993, �Smoke from LargeOil Pool Fires,� pp. 111−119 in Proceedings forthe 6th International Fire Conference,Interfam 93, Fire Safety, London, UnitedKingdom.

NSC (National Safety Council), 2000, WorkInjury and Illness Rates, 2000, Itasca, Ill.

NSC, 2001, Injury Facts, 2001 Edition, Itasca, Ill.

OSHA (Occupational Safety and HealthAdministration), 2001, �Occupational Safety andHealth Standards,� Code of Federal Regulations,Title 29, Part 1910, Subpart Z.

PWS (Prince William Sound Tanker PlanHolders), 1999, Prince William Sound Tanker OilDischarge Prevention and Contingency Plan, BPOil Shipping Company, 2nd Ed., Anchorage,Alaska, Nov.

Rose, D., 1981, The Atlantic Research ChamberApplied Research Report on Monograph, UMTA-GA-0007-79-1, Atlanta, Ga., March.

Schomer, P.D., 1973, Predicting CommunityResponse to Blast Noise, Technical ReportE-17, Construction Engineering ResearchLaboratory, Champaign, Ill., Dec.

Schomer, P.D., 1981, Blast Noise Prediction,Vol. 1: Data Bases and ComputationalProcedures, Technical Report N-98,Construction Engineering Research Laboratory,Champaign, Ill., March.

Sears, F.W., 1964, An Introduction toThermodynamics, the Kinetic Theory of Gases,and Statistical Mechanics, Addison-WesleyPublishing Company, Inc., Reading, Mass.

Shen, H.T. et al., 1988, �Oil Slick Transport inRivers,� ASCE 114(5):529−543.

TAPS Owners (Trans Alaska Pipeline SystemOwners), 2001a, Environmental Report for theTrans-Alaska Pipeline System Right-of-WayRenewal (Draft), Anchorage, Alaska.

TAPS Owners, 2001b, TAPS Right of WayRenewal Oil Spill Database, Anchorage, Alaska,Dec.

TAPS Owners, 2001c, Trans Alaska PipelineSystem Route Maps, Fairbanks, Alaska, July.

Taylor and Associates, 1995, Risk AnalysisScreening Study for the Trans-Alaska PipelineSystem.

Technica, Inc., 1991, Trans-Alaska Pipeline RiskAssessment, Columbus, Ohio, Jan. 19.

APPENDIX A A-58

U.S. Bureau of the Census, 2000, Poverty in theUnited States, 1999, P60-210, Washington D.C.,Sept.

Weast, R.C., 1968, Handbook of Chemistry andPhysics, 49th Ed., Chemical Rubber Company,Cleveland, Ohio.

Weil, J.C., 1982, �Source Buoyancy Effects inBoundary Layer Diffusion,� in Workshop on theParameterization of Mixed Layer Diffusion,R. Cionco (editor), Physical SciencesLaboratory, New Mexico State University,Las Cruces, N.M.

Weil, J.C., 1988, �Plume Rise,� pp. 199−157 inLectures on Air Pollution Modeling,A. Venkatram and J.C. Wyngaard (editors),American Meteorological Society, Boston, Mass.

B-1

Appendix B:

TAPS ROW Map Atlas

APPENDIX B B-2

B-3

Appendix B:TAPS ROW Map ATLAS

This appendix contains a set of 27 maps.The first map is the base map with a legend andkey. The next 26 maps cover the TAPS route.Map 1 starts the series at the North Slope, andMap 26 ends the series at the south end at thebeginning of the tanker lanes in Prince WilliamSound. The maps include the followinginformation:

• TAPS pipeline and facilities, including pumpstations, access roads, and material sites

• Topography

• Place names

• Water bodies and glaciers

• Public Land Survey System with townshipand range labeled

• Roads

• Land ownership of the ROW

• Locations of larger spills

• Visual resource locations

• Conservation system units

• Oil Spill Contingency Plan sites

The maps are plotted at a scale of1:143,400 approximately 1 inch = 2.25 miles).The datum is NAD 27. The projection and thecoordinate system are UTM Zone 5.

APPENDIX B B-4

B-5 APPENDIX B

Click here to view Atlas Key Map

APPENDIX B B-6

Click here to view Atlas Map 01

B-7 APPENDIX B


APPENDIX B B-8


B-9 APPENDIX B


APPENDIX B B-10


B-11 APPENDIX B


APPENDIX B B-12


B-13 APPENDIX B


APPENDIX B B-14


B-15 APPENDIX B


APPENDIX B B-16


B-17 APPENDIX B


APPENDIX B B-18


B-19 APPENDIX B


APPENDIX B B-20


B-21 APPENDIX B


APPENDIX B B-22


B-23 APPENDIX B


APPENDIX B B-24


B-25 APPENDIX B


APPENDIX B B-26


B-27 APPENDIX B


APPENDIX B B-28


B-29 APPENDIX B


APPENDIX B B-30


B-31 APPENDIX B


APPENDIX B B-32

C-1

Appendix C:

Hazardous Materials and Waste Management

APPENDIX C C-2

C-3

Appendix C:Hazardous Materials and Waste Management

C.1 Introduction

Affected environments are defined for eachof the major waste types associated with Trans-Alaska Pipeline System (TAPS) operations. Foreach waste category, the respective AlyeskaPipeline Service Company (APSC)Environmental Management System program,relevant implementing procedures, andinformation obtained through interviews of APSCand Joint Pipeline Office (JPO) representativesare used to describe the general nature of thewastes being generated and the external andinternal controls that govern APSC extantmanagement strategies. The most recentlyavailable disposal records are used to providequantification where possible. Informationprovided in the Hazardous MaterialsManagement Business Model and its relatedimplementation procedures is used to define theaffected environment with respect to hazardousmaterials. Quantities of some hazardousmaterials are reflected in the APSC EmergencyPlanning and Community Right-To-Know(EPCRA) Tier II report for 2000.

C.2 Hazardous MaterialsManagement

Hazardous materials are used throughoutthe TAPS system to support operations andmaintenance. The APSC Hazardous MaterialsManagement Business Model provides for bothadministrative tracking and physical control ofhazardous materials (APSC 2000a). Chapter 8of the TAPS Environmental Protection Manual,EN-43-1 (APSC 2000b), contains implementingprocedures for hazardous materialsmanagement. The more salient elements of theprogram include the following:

• Review and authorization for use: Before achemical can be used within the TAPS(including at contractor facilities), approvalsmust be obtained from both APSCenvironmental and safety authorities. The

safety review identifies the prominentchemical and physical hazards of thechemical and specifies unique storage andhandling requirements as well as thenecessary hazard communication trainingfor workers who will handle, or potentially beexposed to, the chemical. Theenvironmental review identifies thecompliance obligations that result from usingthe chemical and specifies the appropriatedisposal scheme for resulting wastes.Appropriate elements of spill contingencyplanning are also identified.

• Inventory management: A systemwideHazardous Materials Consolidation andRedistribution (HAZCORE) Program is inplace. Databases are maintained on acommercially available computer softwareprogram to provide for systemwidecomprehensive hazardous materialsprocurement and inventory management, aswell as the electronic management anddistribution of Material Safety Data Sheets(MSDS). Initiatives such as redistributinghazardous materials throughout the system,limiting excess hazardous materialspurchases, and tracking material shelf livesare all facilitated by the HAZCOREdatabases. The HAZCORE databases alsointerface with programs for employeetraining to ensure that training is consistentwith Occupational Safety and HealthAdministration (OSHA) and State of Alaskarequirements and APSC corporate policies.

• Hazardous material transportation: Separatetraining on U.S. Department ofTransportation (DOT) requirements isprovided to APSC employees and contractoremployees who repackage and transporthazardous materials throughout the TAPS.

• Hazardous materials management plans:Hazardous materials brought into TAPS

APPENDIX C C-4

facilities by contractors or to support aspecific project require an approvedHazardous Materials Management Plan.Such plans provide details on the materials,their packaging and storage circumstances,appropriate contingency plans, and anidentification of all wastes anticipated fromthe use of the materials in question.

• Emergency planning: Emergency planningincludes the development of site-specificcontingency plans for hazardous materialstorage or usage locations. This programelement also supports APSC�s responsibilityto notify local emergency responseauthorities of all hazardous materialspresent in quantities above their respectivethreshold planning quantities (TPQs) asrequired by EPCRA (also known asSuperfund Amendments andReauthorization Act [SARA] Title III). Inaddition to initial notifications, the program isalso capable of generating an annual reportto the state (known as a Tier II Report) ofamounts and types of hazardous materialspresent at TAPS facilities above TPQs, asalso required by EPCRA.

A wide variety of hazardous materials arenecessary to support the TAPS. Materials usedinclude equipment and vehicle fuels, heattransfer fluids, organic solvents, petroleum-based cleaners and detergents, lubricating oils,adhesives and sealants, refrigerants,photographic materials, fire suppressants, firefighting agents, corrosion inhibitors, corrosiveagents, explosives, and pesticides. In addition,hazardous materials are also used forinfrastructure repair and maintenance. Theseinclude paints and solvents as well as variousadhesives and protective coatings.

In addition to hazardous commodities,hazardous materials are also present in someequipment or products in widespread usethroughout the TAPS. Such products includebatteries of the following types: lead-acid,alkaline, lead calcium, lithium, mercury, nickel-cadmium, and zinc chloride. Other commoditiescontaining hazardous materials include variousitems of air emission monitoring equipment thatmay contain corrosive solutions or toxic heavymetals; thermometers, thermostats, or electricalswitches that contain mercury; vapor or

fluorescent lightbulbs that contain mercury; andincandescent lightbulbs containing lead.

Hazardous materials are delivered to thecentral APSC warehouse in Anchorage, theAnchorage Distribution Center, or directly to theappropriate maintenance facility or pump stationby commercial carriers. APSC employees andoperating contractors also engage in somerepackaging (into smaller containers) andredistribution of hazardous materials throughoutthe TAPS. With few exceptions, hazardousmaterials shipments are by truck (eithercommercial carrier or APSC vehicle).Contractors conducting specific tasks may alsobring hazardous materials obtained from outsidethe APSC inventory directly to the job site. Fuelsare delivered by bulk load by commercialcarriers. With the exception of fuels in portabletanks brought to maintenance or repair worksites along the pipeline and fuels brought toremote gate valve (RGV) control buildings,APSC employees and contractors do notredistribute or otherwise transport fuels.Notwithstanding fuels, hazardous materials arestored in 55-gal or smaller containers.

Although the potential exists for hazardousmaterials to be used anywhere throughout thepipeline or within the Valdez Marine Terminal,the majority of hazardous material usage occursat the marine terminal, the operating pumpstations, and maintenance and equipment yardsoff the TAPS ROW. These locations include theDoyon Industrial Facility (Fairbanks), NordaleStorage Yard (Fairbanks), North Pole MeteringStation, and the Van Horn Facility (Fairbanks).Hazardous materials are also used along thepipeline to support maintenance or repairactivities and special projects. Very smallamounts of hazardous materials are used at theAPSC �Bragaw Facility� administrativeheadquarters in Anchorage. With the exceptionof fuels that are stored in aboveground tanks atpump stations and maintenance yards and inone belowground storage tank at the BragawFacility, hazardous materials are stored indedicated storage areas within buildings at theValdez Marine Terminal, the maintenancefacilities, and the pump stations. For some linemaintenance activities or special projects(e.g., vaulting of check valves), limited quantitiesof hazardous materials and fuels are stored in

C-5 APPENDIX C

temporary facilities or portable tanks at the jobsite through the duration of the job.

In March 2001, the APSC submitted anEPCRA Tier II Report to the ADEC reporting onthe amounts of hazardous materials present atAPSC facilities in amounts above theirrespective TPQs (Ferrell 2001). Table C-1provides a summary of that report.

C.3 Hazardous Waste

Section 3 of the TAPS EnvironmentalProtection Manual, EN-43-2 (APSC 2000c),describes procedures by which any wastegenerated within the TAPS will be evaluated andcharacterized. Section 4 establishes systemwideprogrammatic controls for managing those TAPSwastes that are determined to be hazardouswaste by federal or state regulations. Section 4of the TAPS Environmental Protection Manual,EN-43-2, establishes APSC standards forcontainerization and labeling of hazardouswaste; storage of hazardous waste at satellitelocations and designated storage facilities;inspections and record keeping for storageareas; and pickup and transportation ofhazardous waste to designated permittedtreatment, storage, and disposal facilities(TSDFs). Section 4 also establishes trainingrequirements for personnel responsible formanagement of hazardous waste and requiresthe development of contingency plans for allhazardous waste accumulation and storageareas.

The APSC has determined where hazardouswastes are generated and accumulated and hasgiven notification to the U.S. EnvironmentalProtection Agency (EPA) Region 10 of the statusof these locations (Seward 2001a). TheseAPSC-operated hazardous waste generation/accumulation sites include Pump Station(PS) 1 through PS 12 (excluding those now onstandby); Mainline Refrigeration Units 1, 2, and7; the Ship Escort Response Annex; Ship EscortResponse Base; Valdez Marine Terminal; NorthPole Metering Station; Nordale Yard Facility;Northstar Terminal; Van Horn Facility; NorthPole Laboratory; and Bragaw Facility. Only thehazardous waste management areas at Mainline

Refrigeration Unit 2, Northstar Terminal, and theMarine Terminal are large-quantity generators(i.e., generate more than 2,200 lb hazardouswaste per month). The other sites areconditionally exempt small-quantity generatorsthat generate less than 220 lb of hazardouswaste or 2.2 lb of acute hazardous waste in anymonth.

Some APCS-generated wastes, such asspent fluorescent bulbs and batteries, aremanaged as Resource Conservation andRecovery Act (RCRA) Universal Wastes and areultimately delivered to a disposal facility by theAPSC hazardous waste contractor. Spent leadacid batteries are recycled and therefore are notconsidered RCRA wastes.

Hazardous waste is generated from the useof hazardous materials (e.g., methyl ethyl ketone[MEK]) or the disposal of off-specification orexcess chemicals (e.g., 1,1,1-tricholorethane[TCA]), which the EPA designates as �listedhazardous waste� when they are discarded.Wastes generated from the maintenance ofvarious items of pipeline and Valdez MarineTerminal equipment that display any of the EPA-designated hazardous characteristics(i.e., ignitability, corrosivity, toxicity, or reactivity)are also considered hazardous wastes. Onlylarge-quantity generators are required to file abiennial report with the EPA showing the type ofwaste generated, source of the waste, quantityof waste generated, identity of the hazardouswaste contractor taking the waste, and the typeof disposal facility to which it was shipped. Thus,the biennial report filed in 1999 reflects only thehazardous waste generated and shipped fromMainline Refrigeration Unit 2, NorthstarTerminal, and the Valdez Marine Terminal. Thehazardous wastes reflected in the 1999 biennialreport are shown in Table C-2. Other facilitiesalong the pipeline generate similar hazardouswastes, but in smaller quantities.

As shown in Table C.2, a systemwide total of142,118.9 lb of hazardous waste was shipped offsite in 1999. A major reduction in the generationof hazardous waste has occurred over the years,principally because of better hazardousmaterials management and other pollutionprevention initiatives. For example, 712,000 and310,000 lb of hazardous waste were disposed

APPENDIX C C-6

TABLE C-1 Summary of EPCRA Tier II Report for Calendar Year 2000a

TAPS Facility Hazardous MaterialMaximum Daily

Amount PresentbAverage Daily

Amount PresentbPrincipalHazardc

Bragaw OfficeComplex

Diesel fuel 24,000 gal 18,000 gal F, I

Antifreeze 1,000 gal 1,000 gal I, D

Therminol 44® (heat transfer fluid) 11,500 gal 6,500 gal I


Oakite® 13,125 lb 13,125 lb I


Therminol FF® (heat transfer fluid) 11,500 gal 6,500 gal I



Jet oil II 500 gal 500 gal D

Doyon IndustrialFacility

Lubricating oils 99,999 gal 9,999 gal F, I

Drag reducing agent (Conoco) 10,000 gal 5,000 gal F, I, D

Drag reducing agent (Baker) 39,000 gal 20,000 gal F, I, D

Liquid nitrogen 5,200 gal 2,600 gal P

Drag Reducing AgentInjection Facility


Halon 1301® 99,999 lb 99,999 lb I

Lubricating oil 99,999 lb 99,999 lb F, I

Gasoline 9,999 lb 9,999 lb F, I, D

Diesel fuel 99,999 lb 99,999 lb F, I

Antifreeze 9,999 lb 9,999 lb I, D

Methanol 9,999 lb 9,999 lb F, I, D

Methyl ethyl ketone (MEK) 9,999 lb 9,999 lb F, I

Petroleum solvent, Varsol 18® 9,999 lb 9,999 lb F, P

Transmission fluid 9,999 lb 9,999 lb F, I

Nordale Storage Yard

Used oil 5,000 gal 3,000 gal F, I

North Pole MeteringStation


Citrikleen® (new and waste) 900 lb 450 lb NAd

1,1,1-trichloroethane 500 lb 200 lb I, D

Anchorage OperationsSupport Facility

Stoddard solvent (Naphtha-based) 600 lb 500 lb F, I

C-7 APPENDIX C

TABLE C-1 (Cont.)




Therminol 44® (heat transfer fluid) 18,800 lb 18,800 lb I


Drag reducing agent (Baker) 267,000 lb 267,000 lb F, I, D

PS 1

Diesel fuel 2,931,000 lb 2,931,000 lb F, I

JP-4 aviation fuel 64,000 lb 64,000 lb F, IPS 2




PS 3

Lubricating oils and used oil 24,700 lb 24,700 lb F, I


Lubricating oils and used oil 13,500 lb 13,500 lb F, I

JP-4 aviation fuel 64,000 lb 64,000 lb F, I


Gasoline 23,300 lb 12,000 lb F, I., D


PS 4

Propane 12,000 gal 12,000 gal F, P, I


Sulfuric acid (battery electrolyte) 600 gal 500 gal R, I

Lubricating oils and used oil 3,250 gal 1,500 gal F, I

JP-4 aviation fuel 8,000 gal 4,000 gal F, I

PS 5

Halon 1301® (including weight of storage cylinders)

260,000 lb 260,000 lb P


Corrosion inhibitor 700 gal 350 gal F, I

AFFF (aqueous film-forming foam) (3M)

2,310 gal 2,310 gal


Antifreeze 165 gal 100 gal I, D



Sulfuric acid (battery electrolyte) 600 lb 600 lb R, I

JP-4 aviation fuel 8,000 gal 4,000 gal F, I


260,000 lb 2,600,000 lb P

Gasoline 300 gal 150 gal F, I, D

PS 6


APPENDIX C C-8

TABLE C-1 (Cont.)




AFFF (3M) 1,695 gal 1,695 gal NA


Diesel fuel 1,780,000 gal 1,300,000 gal F, I


Sulfuric acid (battery electrolyte) 4,000 gal 4,000 gal R, I


164,000 lb 164,000 lb P


PS 7




99,999 lb 99,999 lb P

PS 8


Drag reducing agent (Conoco) 10,000 gal 5,000 gal F, I, D


Sulfuric acid (battery electrolyte) 4,000 gal 4,000 gal R, I


Lubricating oil 605 gal 605 gal F, I


32,200 lb 32,200 lb P


Diesel fuel 1,680,000 gal 1,400,000 gal F, I


PS 9

AFFF (3M) 1,450 gal 1,450 gal NA

PS 10 Diesel fuel 12,800 gal 12,800 gal F, I


48,000 lb 48,000 lb P

PS 12 Lubricating oil 99,999 lb 99,999 lb F, I


99,999 lb 99,999 lb P

Gasoline 99,999 lb 99,999 lb F, I, D


Corrosion inhibitor 99,999 lb 99,999 lb F, I

AFFF (3M) 99,999 lb 99,999 lb

Sulfuric acid (battery electrolyte) 500 lb 500 lb R, I

Propane 8,000 gal 4,000 gal F, P, IRGVs 26−37 at PS 4e Diesel fuel 5,821 gal 2,500 gal F, I

C-9 APPENDIX C

TABLE C-1 (Cont.)




Propane 8,000 gal 4,000 gal F, P, IRGVs 39−62 at PS 5e Diesel fuel 5,821 gal 2500 gal F, I

Propane 8,000 gal 4,000 gal F, P, IRGVs 65−77A at PS 7e Diesel fuel 5,821 gal 2,500 gal F, I



SERVS(Downtown)


Corexit� dispersant 100,800 lb 100,800 lbf F, I, Df


Motor oil 4,470 lb 4,470 lb F, I

SERVS (MineralCreek Rd.)

Corrosion inhibitor 9,800 lb 4,900 lb F, I


Ethylene glycol 280,000 lbf 280,000 lbf I, D

Gasoline 7,000 lb 7,000 lbf F, I, D

Hydraulic lubricating oil 80,000 lb 50000 lb F, I

Cleartron ZB-258® 108,000 lb 108,000 lb I

Sodium hydroxide 159,000 lbf 159,000 lbf R, I

Sulfuric acid (both pure and battery electrolyte)

53,000 lbf 53,000 lbf R, I

Aer-o-lite® (3% Green foam) (fire fighting foam) (National foam)

312,200 lb 312,200 lb I

AFFF (3M) 999,999 lb 999,999 lb NA

Valdez MarineTerminal

Fluoroprotein foam (National) 496,000 lb 465,000 lb NA

BioNutrient 2170 280,000 lbf 280,000 lbf I

Crude oil 1.056 billion lbf 1.056 billion lbf,g F

Van Horn Facility Gasoline 1,000 gal 500 gal F, I, D

Transmission fluid 700 gal 470 gal F, I

Propane 300 lbs 30 lbs F, P, I

PF 32 degreaser 200 gal 165 gal F

Motor oil 700 gal 690 gal F, I

Methanol 55 gal 55 gal F, I, D

APPENDIX C C-10

TABLE C-1 (Cont.)




Van Horn Facility Hydraulic oil 500 gal 455 gal F, I

(Cont.) Diesel fuel 26,000 gal 15,850 gal F, I

Antifreeze 500 gal 315 gal I, D


a Except as noted in footnote f, data in this table were derived from the State of Alaska Tier II formssubmitted by APSC to the Alaska Department of Environmental Conservation (ADEC) on March 1, 2001,covering the period January 1, 2000, through December 31, 2000. No attempts were made toindependently verify any of the quantities reported. Storage of hazardous materials in calendar year 2000is believed to be generally representative of ongoing TAPS operations.

b Under the federal regulations governing completion of the Tier II report, the facility may choose to reportthe maximum amount possible rather than provide quantities based on actual throughput (e.g., entriessuch as 99,999 lb).

c Federal regulations provide for three physical hazard categories: Fire (F), Sudden Release of Pressure(P), and Reactive (R). Two health hazard categories are defined: Immediate (Acute) Health Hazard (I) andDelayed (Chronic) Health Hazard (D). These hazard categories are defined in the Code of FederalRegulations, Title 40, Part 370 (40 CFR 370.2).

d NA = not applicable; although they do not meet any hazard categories defined in 40 CFR 370.2, thesechemicals were nonetheless included in the APSC�s EPCRA report for completeness.

e A small building at each gate valve houses controls. The buildings are heated by a propane heater. Eachgate valve building also has a diesel-fired electric generator. The amounts of propane and diesel fuelpresent at each gate valve are very limited. Maintenance crews stationed at pump stations areresponsible for maintaining the gate valves, including supplying propane and diesel fuel to the controlbuildings on an as-needed basis. Supplies of propane and diesel fuel to support gate valves are stored atthe pump stations, as indicated in the table.

f Recent changes in operating circumstances have resulted in different types and amounts being present atcertain facilities. On April 17, 2002, APSC submitted a revised EPCRA Tier II report to ADEC. The data inthis table are from this amended report (Willson 2002).

g This total does not represent crude oil in Tanks 1 and 3. That oil is considered to be in the transportationmode and not subject to EPCRA reporting.

of off-site in 1993 and 1996, respectively (APSCundated).

According to the TAPS EnvironmentalProtection Manual, EN-43-2 (APSC 2000c),wastes are containerized and accumulatedwithin designated waste accumulation areaslocated within buildings. APSC policies requirethat all hazardous waste accumulation areashave secondary containment features; thisrequirement is satisfied by the secondarycontainment features of the buildings or by theinstallation of secondary containment features atthe accumulation areas. Small amounts of

hazardous wastes are also occasionallygenerated along the pipeline ROW as the resultof remote maintenance or repair projects. Allsuch wastes are containerized and brought backto the closest pump station or maintenancefacility hazardous waste accumulation area.APSC contractors are obligated to properlycontainerize, label, and store wastes that theygenerate. Such contractor hazardous wastes areultimately transported to APSC hazardous wasteaccumulation areas for management underAPSC hazardous waste procedures. Hazardouswaste accumulation generally occurs in

C-11 APPENDIX C

TABLE C-2 Hazardous Wastes Generated at the Mainline Refrigeration Unit 2,Northstar Terminal, and VALDEZ Marine Terminal in 1998−1999

Waste DescriptionDisposal Facilityor Technology

Quantity(lb)

Mainline Refrigeration Unit 2

Brine solution from refrigeration units (contaminated with chromium) Off-site POTWa/sewer 5,000.00

Absorbent pad contaminated with brine solution (chromium) Incinerator 2,009.00

Brine (chromium) contaminated pipe Stabilization 2,500.00

Total hazardous waste generated 9,509.00

Northstar Terminal

Spent carbon filters from aerosol can puncturing unit contaminatedwith carbon tetrachloride, methyl ethyl ketone, tetrachloroethylene,dichloromethane, or 1,1,1-tricholorethane

Energy recovery 46.7

Flammable cleaning compound Energy recovery 200.0

Thinners and rags contaminated with solvents Incinerator 420.0

Flammable petroleum residues (gelblok) containing benzene Energy recovery 2,000.0

Flammable used paint, epoxy, and thinners Energy recovery 1,188.0

Petroleum-based product with 1,1,1-tricholorethane (valve cleaner) Incinerator 350.0

Mercury debris (bulb crusher filter) Retorting 10.0

Crushed fluorescent bulbs contaminated with mercury Landfill 2,800.00

Hydrochloric acid POTW/sewer 5.0

Freon gas cylinders Incinerator 100.0

Flammable aerosol can residue, sorbents, and plastic contaminatedwith carbon tetrachloride, methyl ethyl ketone, tetrachloroethylene,dichloromethane, or 1,1,1-tricholorethane



APPENDIX C C-12

TABLE C-2 (Cont.)


Quantity(lb)

Valdez Marine Terminal

Freon 113, oil and water Incinerator 75.0

Silver-contaminated spent photographic chemicals (fixer/developer) POTW/sewer 1,300.0

Flammable adhesives Incinerator 150.0

Used oil with chlorinated compounds Energy recovery 5.0

Oxidizer Incinerator 8.0

Petroleum residues (strainer and filter wastes) contaminated withbenzene

Incinerator 18,260.0

Petroleum residues (steam rack sludge) contaminated with benzene Energy recovery 81,151.2

Used paint, epoxy, and thinners Energy recovery 6,600.00

Spent carbon filters from aerosol can puncturing unit contaminatedwith carbon tetrachloride, methyl ethyl ketone, tetrachloroethylene,dichloromethane, or 1,1,1-tricholorethane

Energy recovery 5.0

Flammable lab pack Energy recovery 225.0

Mercury thermometers Retorting 10.0

Mercury debris Retorting 40.0

Crushed fluorescent bulbs contaminated with mercury Landfill 2,960.0

Crude oil and gravel contaminated with benzene Incinerator 11,000.00

Corrosive spent film fixative contaminated with silver and chromium Landfill 1,250.0

Flammable, reactive zinc dust Incinerator 40.0

Filters contaminated with benzene (used gas filters) Incinerator 95.0

Coolant filters contaminated with lead Landfill 147.0

Labpack contaminated with lead Incinerator 5.0

C-13 APPENDIX C

TABLE C-2 (Cont.)


Quantity(lb)

Valdez Marine Terminal (Cont.)

Toxic labpack contaminated with methylene chloride and 1,1,1-trichloroethane

Incinerator 150.0

Flammable, corrosive, vapor recovery system scale contaminatedwith benzene

Incinerator 120.0

Mercury contaminated sediment Landfill 715.0

Caustic lab pack (alkali) Neutralization 15.0

Acid lab pack Neutralization 165.0

Xylene, methanol, and crude oil solution Energy recovery 90.0

Aerosol can residue, sorbents, plastic contaminated with carbontetrachloride, methyl ethyl ketone, tetrachloroethylene,dichloromethane, or 1,1,1-tricholorethane


Lead contaminated incandescent lightbulbs Landfill 645.0


a Publicly owned treatment works such as a municipal wastewater treatment plant.

Source: Seward (1999).

containers with a 55-gal capacity or less. Thereis no accumulation or storage of hazardouswaste in tanks.

Under the current scheme, the APSCcontractor collects hazardous waste from theaccumulation areas on a regular schedule,weather permitting. Trucks begin the collectionat PS 1 and continue down the pipeline,collecting waste containers from eachdesignated accumulation area along the way.The waste is then consolidated at the hazardouswaste contractor�s transfer facility. No permittedRCRA TSDFs exist within the state of Alaska.Therefore, the APSC hazardous wastecontractor transports all APSC hazardous wasteto out-of-state RCRA-permitted TSDFs. Under a

proper hazardous waste manifest, trucks deliverthe waste to a rail terminal in Anchorage(Burlington 2001). Wastes proceed by rail to aship terminal in Anchorage, where they aretransported by ship or barge to a rail yard in theState of Washington. The wastes are thentransferred by rail to the hazardous wastecontractor�s transfer facility in Washington.Wastes are then sent, via truck, to variousTSDFs in Washington or elsewhere in thecontiguous 48 states, depending on thetreatment, storage, or disposal designated by theAPSC. All wastes are transported in containersmeeting DOT specifications.

Likewise, routinely generated wastes fromthe Valdez Marine Terminal are transported via

APPENDIX C C-14

truck by the hazardous waste contractor toAnchorage, where they follow the same generalpath to out of state TSDFs. Special projects maygenerate substantial quantities of hazardouswaste over short periods of time (e.g., recoveryof tank bottoms) and may require speciallyscheduled pickup and transportation. However,the management of hazardous waste from suchspecial projects is essentially the same as thatdescribed above. In 2001, approximately 4,00055-gallon drums of waste tank bottom sludgewere removed from the Valdez Marine Terminalduring a one-time cleanout project. Because ofprior years of transferring the tank bottoms fromone tank to another to accommodate the tankinspection schedules, this cleanout projecteffectively represents 10 years of tank bottomsbuildup. This buildup was characterized ashazardous and is being shipped out via theAPSC hazardous waste contractor under propermanifests to appropriate, permitted out-of-stateTSDFs.

During early years of operation of thepipeline, three �Topping Plants� were operationalat PS 6, 8 and 10. These Topping Plants wereinitially operated to provide refined petroleumproduct for use as fuel for APSC equipment andvehicles. Thus, the Topping Plants met theRCRA definition of a petroleum refinery, andvarious EPA-designated listed hazardous wastecan be expected from their operation. However,once commercial fuel outlets became availablein areas along the pipeline route, the APSCdetermined that continuation of the ToppingPlants was no longer cost-effective. The plantshave been �mothballed� and are not expected togo back into service in the foreseeable future.Therefore, no additional impact analyses areprovided for wastes related to Topping Plantoperations.

Spill debris (e.g., contaminatedenvironmental media, spent absorbent pads, andother items used in spill response) may behazardous waste. When unplanned releases ofcrude oil, refined petroleum product, orhazardous material occur along the mainline,circumstantial factors of such releases maydictate temporary storage of contaminateddebris at the spill site. When logistics permit,such contaminated debris will be containerizedor otherwise impeded from further environmental

impact until adequate characterization of thedebris is completed. Temporary storage plansmay also need to be developed and approved bythe ADEC. Such plans may allow for storage atthe spill site or at pump stations nearest the spillsite for a period of up to two years, or at theValdez Marine Terminal for periods of up to fouryears.

Ultimate disposition of contaminated mediaand spill debris is addressed on a case-by-casebasis in remediation and restoration plans thathave been approved by the appropriate JPOmember agencies. However, extended bulkstorage of spill debris that has been determinedby analysis to be hazardous waste is notaddressed. All hazardous waste spill debris iscontainerized and handled in accordance withextant hazardous waste managementprocedures. (See Section 3.16.5 for additionaldiscussion on the management of nonhazardousspill debris and related remediation wastes.)

C.4 Solid Waste

The APSC has established administrativecontrols for the management of all solid wastesgenerated throughout the TAPS. Guidelines areprovided in Section 5, Waste Management, ofthe TAPS Environmental Protection Manual,EN-43-2 (APSC 2000c). Various arrangementsare in place for the management and dispositionof solid wastes. These include incineration,followed by landfilling of resulting ash inpermitted landfills, direct landfilling of some solidwaste in APSC- or municipally owned permittedlandfills and recycling. Explicit guidelines areprovided for all anticipated solid waste streams.

Both domestic and industrial solid wastesare generated at various locations throughoutthe TAPS. Domestic solid waste results primarilyfrom the operation and maintenance ofpersonnel living quarters and support facilities,such as kitchens and cafeterias located at thepump stations and maintenance andadministrative facilities. Common office wastesalso fall into the category of domestic solidwastes. Industrial solid wastes are generated atpump stations, mainline refrigeration units, andoff ROW maintenance facilities as well as at theValdez Marine Terminal.

C-15 APPENDIX C

____________________________

1 Class III Municipal Landfills are defined in ADEC regulation 18 AAC 60.300(c). Class III landfills are those that arenot connected by road to Class I landfills or are at least 50 mi distant from Class I landfills. By rule, Class IIIlandfills are limited to no more than 1 ton per day of ash from incinerated solid waste and less than 5 tons per dayof municipal solid waste. However, the operating permits impose additional restrictions on the wastes that can bedisposed of in APSC landfills.

Solid waste incinerators are located at PS 1through 7 and PS 10 and at the Valdez MarineTerminal. However, incinerators located at pumpstations that are now on standby (PS 2, 6, and10) are not operational. Solid waste incineratorsoperate under the auspices of ADEC-issued airquality operating permits (ADEC 1996). In allinstances, one operating permit addresses allstationary air emission sources at the pumpstation and the Valdez Marine Terminal. Solidwastes that are incinerated include oily wastematerials (but not used oil), shreddeddocuments, kitchen wastes, untreated wood,empty containers, and non-hazardous paintwaste as well as domestic solid waste.Hazardous wastes are not incinerated in APSCincinerators. Operating records indicate that thecumulative amounts of solid wastes incineratedat the APSC incinerators have steadily declinedsince 1994. Estimated amounts of solid wasteincinerated during calendar years (CYs) 1994through 2000 are 1.65, 1.23, 1.17, 0.94, 0.93,0.87, and 0.74 million pounds, respectively(APSC undated; Seward 2001b). Althoughoperating permits issued by the ADEC do notspecify a limit to the amount of solid waste thatcan be incinerated, they do require that APSCbase its waste management decisions on ahierarchy consistent with that established in thePollution Prevention Act of 1990: �1) minimizepollution entering the air, land, and water; and 2)promote waste management practices in thefollowing order of priority: source reductions,recycling/reuse, treatment, and disposal� (ADEC1996).

Statistically relevant sampling over time ofincinerator ash has shown the ash to benonhazardous, provided waste segregationcontrols remain in effect (APSC 2000c).However, the City of Valdez and the Boroughs ofNorth Star and North Slope require laboratoryanalyses verifying nonhazardous character foreach delivery of ash to their facilities.Consequently, each shipment of ash fromincinerators at PS 1 and 2 and the ValdezMarine Terminal is sampled for hazardous

characteristics before delivery to designatedlandfills. Ash from all other incinerators issampled annually. Sampling and analysis of ashfollow the prescriptions of approved EPA testmethodologies (EPA 1986). Ash thatdemonstrates hazardous waste characteristics ismanaged within APSC as hazardous waste andis collected by APSC�s hazardous wastetransporter for delivery to out of state TSDFs.

The APSC maintains three solid wastedisposal sites (SWDSs), SWDS 117-1B, 100-1,and 38-1. Each disposal site is permitted byADEC as a Class III Municipal Landfill (Seward2001b,c).1 All three permits were renewed inSeptember 2001 and have expiration dates ofJuly 31, 2006.

SWDS 117-1B is located approximately 1 misouth of Dalton Highway MP 285, Sections 28and 33, T.9S, R.12E, Unimat Meridian. SWDS100-1 is located approximately 1.5 mi south ofWiseman, Alaska, in Sections 25 and 36, T.30N,R.12W, Fairbanks Meridian. SWDS 38-1 islocated approximately 1 mi south of PS 10 inSection 25, T.17S, R.10E, Fairbanks Meridian.(Seward 2001c) The APSC landfills arepermitted to receive ash from the solid wasteincinerators at PS 3, 4, 5, 6, 7, and 10 and theValdez Marine Terminal, as well as inertconstruction wastes, including nonsalvageablemetals and other miscellaneous nonhazardoussolid industrial wastes from APSC facilities.

Wastes prohibited from disposal in theAPSC-operated landfills include any hazardouswaste as defined by 40 CFR 261.3, oily waste,waste oil, greases, paints, sludge, chemicalwastes, putrescible waste that has not beenincinerated, and medical waste that has notbeen sterilized. Certain restrictions are alsoplaced on the receipt of contaminated soil.Disposal options for contaminated soils andother remediation wastes resulting fromresponses to accidental releases of crude oil,refined petroleum products or hazardousmaterials are addressed in Section 3.16.5. In

APPENDIX C C-16

accordance with conditions in the operatingpermits for the three APSC-operated landfills,APSC personnel maintain a solid wasteoperating log at each of the facilities that deliverwastes to any of the APSC landfills. The APSCalso develops and submits quarterly reports oflandfill operations to the ADEC. These reportsinclude amounts and types of waste disposed ofand completed APSC-developed inspectionchecklists that incorporate all performancestandards contained in the ADEC-issuedoperating permits as well as amended �As-built�landfill plans. For landfill 117-1B only, the permitrenewal issued in September 2001 by the ADECcalls for the APSC to annually sample surfacewater ponded in the disposal cell, analyze forparameters contained in the landfill�s EnhancedManagement Plan, and submit the results to theADEC. The first such sampling event under therenewed permit has yet to occur.

The APSC also utilizes eight municipallyowned and operated landfills for disposal of solidwastes generated throughout the TAPS.Information on these landfills and the APSClandfills and the manner in which all are currentlyutilized is provided in Table C-3.

At most locations, the APSC maintainsservice contracts with local commercial wastehaulers for the collection of solid wastes from itsfacilities and delivery to the specified landfill.Municipal employees provide this collection andhauling service in Valdez as part of themunicipality�s solid waste disposal service.Valdez Marine Terminal personnel, however,can also deliver solid wastes directly to eitherthe Valdez sanitary landfill or the Valdezconstruction debris landfill. APSC employeescollect and deliver wastes from APSC facilities toany of the three APSC-operated landfills. Detailson the management of asbestos waste areprovided in Section 3.16.5.

The APSC also maintains a number ofrecycling programs for some solid wastestreams. The solid wastes for which recyclingoptions have been identified are preciousmetals, scrap metals, aluminum beverage cans,copy machine toner cartridges, thermostats andthermometers (mercury containing), asphalt,nonhazardous spent sandblasting sand and grit,wood, office furniture, waste office paper, and

newspaper. However, the extent to which eachrecycling program is active at any given time isdependent on the viability of recycled productmarkets as well as other circumstantial factors.Some solid wastes (e.g., office paper, spent heattransfer fluids) are also burned as supplementalfuel. Table C-4 provides the latest available dataon APSC recycling activities.

C.5 Wastewater

The Ballast Water Treatment Facility(BWTF) treats ballast water and otherwastewater from Valdez Marine Terminaloperations. Its general components aredescribed in the Best Management PracticesPlan for Ballast Water Treatment (APSC 2001b).The BWTF includes ballast water storage tanks(90s tanks), dissolved air flotation (DAF) cells,biological treatment tanks (BTTs), air strippers, achemical storage/injection system, control room,laboratory, and oil recovery tanks (80s tanks).The 90s tanks provide primary gravity separationof separable solids and free-phase oil, and allowcontainment of spills or equalization of flowvariations. The DAF cells further reduce free-phase separable and dissolved hydrocarbons byenhancing phase separation through release ofwater supersaturated with air. The BTTscontinue the treatment process by biologicallydegrading most residual levels of dissolvedhydrocarbons and other organic wastes still inthe waste stream. Finally, air strippers may beused to prevent exceeding the BWTF�s permitlimit for BTEX (benzene, toluene, ethylbenzene,xylene) if biological treatment is insufficient.

The BWTF also includes an �oil recoverysystem.� The 90s tanks, DAF cells, and BTTsrecover oil in the wastewater through skimming,which in turn is hardpiped to the 80s tanks. In the80s tanks, the recovered oil is separated fromthe wastewater through gravity separation.Recovered oil from the 80s tanks is hardpiped tothe Valdez Marine Terminal oil transfer systemand becomes a part of the crude oil loadedonboard tankers or stored with the crude oil inthe marine terminal crude oil storage tanks untilit is loaded onboard tankers. Wastewater fromthe 80s tanks is routed by hardpiping to the 90stanks for treatment by the BWTF.

C-17 APPENDIX C

TABLE C-3 Solid Waste Disposal Sites Currently Used by APSC

Owner/OperatorDisposal

Site NamePermit

NumberAPSC FacilitiesUsing This Site

AmountDelivereda,b

APSC SWDS 117-1B 0131-BA006 PS 3 and 4 073 (first twoquarters of 2001)

APSC SWDS 100-1 0131-BA005 PS 5, 6, and 7 208.811.1 (first twoquarters of 2001)

APSC SWDS 38-1 0132-BA003 PS 10, VMT 72520 (first twoquarters of 2001)

North Slope Borough Oxbow Landfill 9536-BA006 PS 1, 2, 3, and 4 NAc

North Star Borough South CushmanLandfill

9131-BA005 PS 7 and 8, VanHorn, Nordale Yard,Doyon IndustrialFacility, North PoleMetering

1,608

City of Delta Junction Delta Landfill 8833-BA002 PS 9 NA

Copper BasinSanitation ServicesCompany

GlennallenLandfill

9022-BA001 PS 12 1,950

City of Valdez Valdez CityLandfill

8224-BA001 VMT, SERVSd 1,450e

City of Valdez ValdezConstructionDebris Landfill

9322-BA001 VMT, SERVS 40e,f

Municipality ofAnchorage RegionalLandfill

MunicipalLandfill

8721-BA018 BragawAdministrativeCenter, otherAnchoragefacilities, otherfacilities outsideAnchorage withspecial permission

880 wastef,g

208 cardboardh

(Over the periodNov. 12, 2000, toNov. 12, 2001)

City of Palmer�Matinuska-Susitria�or Mat-Su

Palmer Landfill Asbestos wastesfrom all APSCfacilities (with priorapproval)

Data not availableg

APPENDIX C C-18

TABLE C-3 (Cont.)

a Amount delivered is reported in uncompacted cubic yards. Latest available data are displayed and areconsidered to be representative of annual waste volumes routinely generated. Reporting period isCY 2000 unless otherwise specified.

b Volumes of solid waste delivered to APSC-operated landfills were compiled from quarterly reportssubmitted to the ADEC in accordance with operating permit provisions. Landfill operators provideddata on waste volumes delivered to municipal landfills to the APSC (Seward 2000a−c, 2001d−g,2002a).

c NA = data not available

d VMT = Valdez Marine Terminal; SERVS = Ship Escort/Response Vessel System.

e Volumes of solid waste delivered to City of Valdez landfills were compiled from billing statementsissued by the City of Valdez (APSC 2000d). All volumes are reported in cubic yards and areapproximate.

f Volumes of construction and demolition waste delivered to the City of Valdez Construction Debrislandfill by APSC personnel are not represented in this total. However, these volumes are consideredto be inconsequential to the total amount delivered.

g Normally, solid waste is collected at the Bragaw facility in a compactor. However, temporarily stagedroll-off containers were also used during the reporting period. Approximately 800 yd3 of compactedsolid waste were removed over the reporting period and represent approximately 86.23 tons. Theremaining 80 yd3 of uncompacted solid waste collected in roll-off containers represent an additional32 tons. Presumably, the landfill operators were able to recycle the 208 yd3 of cardboard collectedover the reporting period.

h APSC personnel report that the Palmer landfill is used exclusively for disposal of asbestos containingwaste resulting from asbestos-containing material removal/remediation actions, and then only whenthe resulting volumes are large enough to make shipment to Palmer cost effective. Alternatively,small volumes of asbestos waste are shipped out of state together with hazardous waste (Seward2002b).

The industrial wastewater sewer system(IWSS) is an integral component of the ValdezMarine Terminal and is designed to routeindustrial wastewater to the BWTF (e.g.,incidental spills, oily water, potentiallycontaminated storm waters, and processwastewater). Areas served by the IWSS thatmay contribute contaminants from spills or leaksare the tank farms; power generation/vaporrecovery area; fuel storage and loading areas;emergency response building/administrationarea (which includes the laboratory and ottercleaning station); fire training grounds; sludgetank area; transformer dike areas; berths; firepump buildings; west metering facilities;maintenance/warehouse area; SERVS; andSERVS contract vessels, including tank vesselescort tugs, discharge bilge waters, and oil spillwaters. Drainage to and through the IWSS in the

upper Valdez Marine Terminal area is by gravity.Water and contaminants are contained by dikesand drain through the sewer lines to the ballastwater headers. Flow from the various areas iscontrolled by valves. A chemical sewer line fromthe vapor recovery area is used to routescrubber water, effluent knockout water, vaporrecovery water condensate, and boilerchemicals directly to the BWTF 90s tanks.

Wastewater is discharged from the ValdezMarine Terminal pursuant to a National PollutantDischarge Elimination System (NPDES) permitissued by the EPA, Region 10, effective May 21,1997 (APSC 1997). The Valdez Marine Terminalis authorized to discharge treated ballast andbilge water, storm water, and other wastewatersfrom a submarine outfall near Berth 3 into thePort of Valdez. Only treated wastewaters that

C-19 APPENDIX C

TABLE C-4 APSC Recycled Waste Types, Sources, Disposition, and Amounts

Material Sourcea Disposition Year/Amountb

Office paper Doyon IndustrialFacilityc

Delivered to Eielson Air Force Basefor use as supplemental fuel in thepower plant

1999/350 yd3

Mixed paper APSC employeeresidences

Delivered to Eielson Air Force Basefor use as supplemental fuel

1999/150 yd3

Copy machine tonercartridges

FBU Returned to manufacturer 1999/307 units

Copy machine tonercartridges

Anchorage,VMT, and somepump stations

Returned to manufacturer 1999/576 units

Aluminum (beveragecans, printing plates)

Systemwide Sent to aluminum recycler (deliveryhad not yet occurred as of April 10,2000)

1995/8,408 lb1996/6,345 lb1997/992 lb1999/8 yd3

Styrofoam packingpeanuts

FBU Given to commercial mailing servicefor reuse

1999/64 lb

Therminol (heattransfer fluid)

Systemwide Sent for burning as supplementalfuel

1999/18,000 gal

Lead-acid batteries Systemwide Returned to manufacturer forrecycling

1995/5,990 lb1999/51,408 lb2000/38,700 lb

Scrap metal Systemwide Sent to metal recyclers 1995/795.52 tons1996/984.34 tons1997/1,065.91 tons1999/910.44 tons2000/548.95 tons

Freon Systemwide Recovered for reuse 1999/759 lb

Cardboard Systemwide Sent to recyclers, reused, distributedto employees for home use

1997/5,912 lb

Antifreeze Systemwide Returned to manufacturer forreprocessing

NAd

APPENDIX C C-20

TABLE C-4 (Cont.)

a APSC = Alyeska Pipeline Service Company; FBU = Fairbanks Business Unit (Doyon IndustrialFacility); VMT = Valdez Marine Terminal.

b Latest available data are displayed. Data were derived from an internal APSC memorandum aswell as from a draft report on APSC recycling programs (Seward 2000d; APSC 2001a).

c Includes FBU administrative offices at Doyon.

d NA = data not available.

originate from sources listed in the BestManagement Practices (BMP) Plan may bedischarged through Outfall 001. Any wastestream not listed in that document or inquantities significantly greater than theestimated amounts listed in the BMP Plan arenot to be discharged without prior authorizationof the EPA, in consultation with the ADEC.These waste streams and estimated averageflow are shown in Table C-5.

On a volume basis, tank vessel dischargesof ballast and bilge water account forapproximately 93% of the total wastewaterprocessed by the BWTF (APSC 2001b).Influents that are primarily oil are routed to theBWTF oil recovery system or injected into thecrude stream at the east metering building sump.Influents that are primarily water are introducedinto the BWTF through the 90s tanks.

The BWTF effluent flow averages inCY 2000 are shown in Table C-6. The totalBWTF effluent flow for 2000 was3,785,050,000 gal.

The BWTF permit establishes effluent limitsfor BTEX, total suspended solids (TSS), flow,and pH. It also contains detailed, periodicmonitoring and reporting requirements for bothinfluents and effluents. In addition, the permitalso sets out detailed mixing zones wherehuman health and chronic aquatic life criteriasampling and analysis apply. The BMP Planestablishes specific practices to control thequality of incoming ballast from tankers and bilgewaters from SERVS and contracted vessels.

Sludge accumulates in the bottoms of the90s tanks, the DAF cells, and the BTTs. Sludgeof similar composition also accumulates in

sumps and portions of the IWSS. The 80s tanksare hybrid tanks because they act as bothwastewater treatment tanks and recovered crudeoil storage tanks. The 80s tanks recovered crudeoil is routinely routed to the crude oil storagetank or directly onto a tanker. The heavier crudeoil components, commonly called �tankbottoms,� are treated the same as crude oil tankbottoms and are also routed to crude oil storagetanks or onto tankers. If maintenance orinspection of the 80s tanks is necessary, therecovered crude oil and tank bottoms will berouted to the crude oil storage tanks or tankers.Normal maintenance requires periodic cleaningof the BWTF tanks and the IWSS. The removedsludges are not reintroduced into the treatmentsystem.

Sludge that is transferred from the tanks intocontainers must be managed as a solid waste,including sampling to determine if it is ahazardous waste (e.g., exceeds the toxicitycharacteristic levels for benzene). If it is ahazardous waste it is accumulated and managedas hazardous waste and removed by thehazardous waste contractor. Even if it is not ahazardous waste, because of its highhydrocarbon content, it is not disposed of to thelocal landfill but is transported off-site for thermalremediation.

The APSC also holds a NPDES Permitauthorizing discharge from various sites alongthe 800-mi route of the TAPS, effective June 30,1993 (EPA 1993). This permit governs four typesof discharges, secondary containmentdewatering, excavation dewatering, hydrostatictesting wastewaters, and domestic sanitarywastewaters from MCCFs. A Notice of Disposal(NOD) must be submitted to the EPA for eacharea where excavation dewatering discharges in

C-21 APPENDIX C

TABLE C-5 Ballast Water Treatment Facility Influent Sources at Valdez MarineTerminal

Waste Streama

EstimatedAverage Flow

(bbl/d)b Descriptionc

Chemicals for watertreatment maintenance/processing/analysis

0.40 Dilute solutions of caustics, acids, solvents, and inorganic saltsfrom regeneration of ion-exchange resins used to treat boiler feedwater, for maintenance such as piping repairs, and for wateranalysis from process monitoring.

Concentrate fire foam 2.00 Proprietary foam concentrates used as fire fighting agents,Mixtures generally include protein hydrolysate, glycol solvents,fluorosurfactants, hydrocarbon surfactants, inorganic salts, andwater. Sources include incidental leakage and equipmentmaintenance activities.

Fire waterd 3,000.00 Salt water used for fire protection, fire training at the fire traininggrounds, snow removal from tops of 80s and 90s tanks, andpressure testing lines or vessels.

Dilute fire foame 50.00 Mixture of fire foam concentrate and fire water that is also used insumps for vapor suppression to allow for hot work and for firetraining.

Waste glycol <0.10 Incidental leakage from vehicle cooling systems.

Dilute glycol 2.00 Mixture of glycol and water used for cooling and maintenance ofstationary equipment.

Potable, raw saltwater 240.00 Primary source of continually flowing emergency eyewash stationsat the vapor recovery/power generation plant and BWTF/OilRecovery Building. May also include safety shower dischargesthat may contain trace amounts of chemicals, petroleum orgrease. Raw, potable, and salt water may contain residualproducts associated with periodic maintenance activities on fire,fuel, ballast, or crude systems. Pipe lining activities may generateresidual products associated with in-situ lining operations.

Rain and snow melt 11,000.00 Precipitation collected as surface runoff from contained drainageareas. May contain free oil, dissolved hydrocarbons, andsuspended solids. Trace amounts of nitrogen and phosphorousmay be present because of the application of fertilizer on soilsexposed to crude oil or diesel fuel as a result of surface spills orsubsurface leakage from tanks or piping. The fertilizer is applied topromote hydrocarbon biodegradation in contaminated soilslocated in secondary containment areas for crude oil, diesel fuel,or ballast water tankage. May also contain contaminants from thecontaminated soils storage area. Roadway, equipment, and tankde-icing products may be present from the application of de-icingproducts during winter months. The de-icing products are primarilycomposed of mineral salts designed to meet various applicationdemands.

APPENDIX C C-22

TABLE C-5 (Cont.)

Waste Streama



Scrubber water 1,500.00 Water used to absorb SO2 from boiler flue gas prior to introductioninto the vapor recovery is mixed with caustic solution. Scrubberwater contains sodium compounds, sulfates, sulfites, hydroxides,and carbonates at a pH of approximately 2.0 to 8.0.

Boiler blowdown 2,000.00 Water discharged from steam boiler circuit to prevent buildup ofscale, corrosive substances, and corrosion products. Containsinorganic salts and dilute boiler treatment chemicals.

Filter backwash 14.00 Combination of fresh water and glacial silts from treating water forpotable consumption and boiler water make-up and vaporrecovery compressor suction filters. Water filter backwashincludes some carryover from charcoal sand and resin beads.Vapor recovery filter backwash contains iron oxide and tracehydrocarbons and is sent occasionally to the 80s tanks or sludgetank, depending on availability, and primarily to the 90s tanks viathe IWSS.

Washdown water 300.00 Water and steam condensate collected during washdown ofmobile and spill contingency equipment and stationary equipmentand facilities. Contains small amounts of crude oil residues, rustresidues, dissolved hydrocarbons, free phase crude oil, diluteglycol, floor/vehicle wax, lubricating oils, degreasers, water solubledetergents, and soil/sediment.

Dry fire fighting chemical 3.00 Chemical fire extinguishing agent that is a dry mixture ofmonoammonium phosphate, ammonium sulfate, mica, clays,methyl hydrogen polysiloxane, and pigment.

Knockout water f 121.00 Water from the oil/water separation drum at a pH of 1.8 to 7.0,which is anticipated to contain some dissolved hydrocarbons.

Degreasers <1.00 Primarily kerosene-based used to remove crude oil and crude oilresidues from parts and equipment. May occasionally includesmall amounts of water-soluble detergents to remove oil and/oroily residues form parts and equipment. May contain freehydrocarbons, dissolved hydrocarbons, surfactants, ethers,amines, alkyl solfonates, and chelating agents. Use of chlorinatedsolvent is allowed, providing that any such spent liquid solvent willnot be discharged to the BWTF.

Diesel fuel 1.00 Incidental leakage from hoses, vehicles, stationary equipment,draindown of loading arms, and spills during fuel transferoperations.

Gasoline <0.03 Incidental leakage from hoses, vehicles, operations, and firetraining.

C-23 APPENDIX C

TABLE C-5 (Cont.)

Waste Streama



Lubricating oils 0.03 Incidental leakage from pump seals, bearings, and vehicles. Themajority of spent lubricating oils are collected and injected into thecrude oil system.

Hydraulic fluids <0.03 Incidental leakage from pumps, valve actuators, and vehicles. Themajority of spent hydraulic fluid is collected and injected into thecrude oil system.

Transformer fluid g Highly refined petroleum distillate used in high voltage capacitorsand transformers. Does not contain PCBs. Normally notdischarged to the BWTF; incidental leakage or spill fromcatastrophic transformer failure would be collected.

Crude oil 2,000.00 Primary sources are tanker ballast, draindown of loading arms,and sample tap blowdowns at metering facilities.

Crude oil residues 0.333 Major sources are cleaning of pipeline scraper pigs and oil spillcontingency equipment.

Crude oil and diesel tankwater draws

786.00 Mixture of produced brine, minor amounts of fresh water, bottomsediments, dissolved hydrocarbons, and free-phase crude oilperiodically removed from the bottom of crude oil and dieselstorage tanks. Trace constituents from routine activitiesassociated with operational and maintenance activities of oilproduction fields and the pipeline may include corrosion inhibitors,methanol, glycol, fire foam, nonhalogenated cleaning agents, andemulsion reduction agents.

Tank cleaning solution 370.00 Mixture of water, dissolved hydrocarbons, drag reducing agent,crude oil, diesel, and heavy-duty emulsifying cleaner (containingsurfactants, monoaromatic hydrocarbons, diaromatichydrocarbons, and terpenes). Usage rate for undiluted cleaner isapproximately 100−500 gal/yr, depending on the number of tankscleaned.

Hydrotest water 27.00 Mixtures of fresh or salt water and crude oil or petroleum productscollected during pressure testing of crude oil loading arms atberths and/or other process piping and tanks at the VMT, ororiginating from tankers, tugs, escort vessels, barges or otherAPSC/SERVS service vessels. May include up to 1 ppm of IntracidRhodamine W + liquid dye.

APPENDIX C C-24

TABLE C-5 (Cont.)

Waste Streama



Oil spill cleanup water 2,500.00 Highly variable mixtures of fresh water and/or salt water, dissolvedhydrocarbons, sediments, crude oil residues, petroleum productresidues, trace amounts of dispersants and emulsion breakers,and oil spill cleanup chemicals from cleaning of equipment.Sources may include storm-water runoff from temporary spilldebris collection sites, bilge waters from vessels involved in spillcleanup, and oily water (including degreasers) collected duringcleanup activities, including cleanup of equipment. For tankercrude oil spills resulting from tanker structural failures, agencynotification will be made prior to discharge to the BWTF.

Tanker ballast 400,000.00 Harbor water, river water, and/or sea water added to vessel ballastspaces to maintain ship stability. Generally, a mixture of water,salts, suspended solids, dissolved hydrocarbons, 0.5−1.5% crudeoil, and occasionally hydrogen sulfide. May include bilge water,cleaning agents, and crude oil produced water with associatedconstituents, but may not include machinery space oils.

Oil recovery system waterdraws

5,000.00 Clarified wastewater separated by gravity in the 80s tanks. Inputsto the 80s tanks are recovered crude oil skimmed from 90s tanks,DAF float, BTT skimmings, oily waters from cleaning pipelinescraper pigs and oil spill recovery equipment, rain and snow meltfrom diked areas not connected to the IWSS (e.g., sometransformer areas and maintenance/warehouse building sump),and, as necessary, oily wastewater from spill cleanup operationswhen free oil content exceeds that of typical tanker ballast.Clarified wastewater from 80s tanks may contain inorganic salts,suspended solids, dissolved hydrocarbons, H2O2 residuals,glycol, small quantities of free oil, dilute fire foam, and hydrogensulfide.

Service vessel bilges andslops

26.60 Bilge water from SERVS vessels and its contract vessels(including water, salts, and incidental volumes of used oil, diesel,degreasers, and engine coolants) sent to the 90s tanks via theIWSS or vacuum truck or direct piping. Segregated used oildischarged to the VMT does not enter the BWTF.

Sludge processing filtrate 33.00 Water derived from dewatering operations. Containsapproximately 1% crude oil, inorganic salts, dissolvedhydrocarbons, suspended solids and trace amounts of glycols,oxyalkylated fatty acids, bacteria, polymer, enzymes, surfactantsand nutrients. Estimated average flows are averages, but sludgeprocessing usually occurs only once per year. Total quantity ofwater generated during each sludge processing event isapproximately 400,000 to 500,000 gal. Sources include the ballastwater treatment tanks, recovered crude oil tanks, crude oil, andother petroleum storage tanks.

C-25 APPENDIX C

TABLE C-5 (Cont.)

Waste Streama



Hydrogen peroxide 2.00 Commercial-strength solution of H2O2 injected on an as-neededbasis to control hydrogen sulfide in tanker ballast and crude oilrecovery system water draws. Sulfide control is necessary as ahealth and safety measure and to avoid upsets in the biologicaltreatment system.

Dilute polymer 5.00 Approximately 1% solution of cationic, high molecular weightpolyamine added as a flocculant at DAF to enhance separation offinely dispersed oil and suspended solids.

Nutrient 8.00 Solution of urea, ammonia, and phosphate added to DAF effluentto stimulate microbiological activity in BTTs.

Corrosion inhibitors 2.00 Minimal amounts of corrosion inhibitor compounds added to thecrude oil piping at the VMT to control corrosion. The inhibitors arecomposed of proprietary mixtures of oil and water-soluble aminesin an alcohol carrier fluid. The inhibitors contain no heavy metalsor priority pollutants. Trace residuals of these compounds may bepresent in crude tank water draws.

Chemicals used forlaboratory tests

<0.10 Substances used for water testing at the analytical laboratory,BWTF Sample Room, and Powerhouse Water Treatment Room asfollows: dilute aqueous solutions of acids, caustics, salts,hydrocarbon-based solvents, alcohols, ketones, aldehydes,unused standardization and calibration solutions, unused samplesof water (including potable water, ballast water, boiler feedwater,steam condensate, and fire foam water). No halogenated solventsare disposed of in this waste stream.

Wildlife wash water 2,000.00 Mixture of water, oil, and household detergents from cleaningwildlife members that have been oiled (is not routinely generated).

Groundwater 1,400.00 Groundwater that is slightly contaminated with petroleumhydrocarbons as a result of surface spills or leaks of thesematerials from tankage or piping at the VMT.

Hydrochloric acid 0.13 HCl acid injected into the sampling line for the on-line BTEXanalyzer to control the growth of microorganisms within this line.The analyzer provides data that can be used to determine whenthe air strippers will be activated. The biogrowth interferes with theanalyzer�s ability to accurately measure BTEX concentrations.

Gray water 40.00 Water from kitchen, bathroom, and mop sinks, washing machines,and floor cleaning activities in the BWTF Control Building,Emergency Response Building, Administration Building, MarineBuilding, and Maintenance Warehouse. These sources do notinclude human wastes. They may contain small amounts of crudeoil residues, dissolved hydrocarbons, soil/sediment, water-solubledetergents, floor wax, and household wastewater (excludinghuman wastes).

APPENDIX C C-26

TABLE C-5 (Cont.)

a These waste streams are not always part of the influent stream and may enter on a seasonal or even relatedbasis.

b Quantities shown for each waste stream are estimated from consumption and meteorological data. The numbersshown are only averages.

c Abbreviations: BTT = biological treatment tank; BWTF = Ballast Water Treatment Facility; DAF = dissolved airflotation; H2O2 = hydrogen peroxide; IWSS = industrial wastewater sewer system; PCB = polychlorinatedbiphenyl; SERVS = Ship Escort/Response Vessel System; SO2 = sulfur dioxide; VMT = Valdez Marine Terminal.

d More firewater is generated in winter than in summer.

e Approximately 70 bbl of dilute fire foam is generated during fire training exercises.

f More knockout is generated in spring than in winter.

g Waste not routinely generated; enters BWTF on emergency basis only.

Source: Modified from APSC (2001b).

TABLE C-6 Ballast WaterTreatment Facility EffluentFlow Averages in 2000

MonthVolume

(million gal/d)

January 13.3February 12.0March 12.0April 12.7May 11.1June 7.8July 7.1August 8.5September 9.1October 9.9November 10.1December 10.8Average daily flow 10.37

Source: APSC (2000e).

excess of 500,000 gal will take place. NODs arealso required for discharge of hydrostatic testingwastewater in excess of 30,000 gal or dischargeof domestic wastewater in excess of 500 gal.

The average volumes for dischargesaddressed in the linewide NPDES permit, as

calculated in preparation for the 1998 renewalapplication, are shown in Table C-7.

The permit establishes effluent limitationsand, if the discharge reaches receiving waters,monitoring requirements. The permit alsoestablishes acceptable types of treatment andcontrol methods for excavation sites dependingupon seasonal, topographic, vegetative, soil andreceiving water conditions (e.g., a discharge toareas of ice in a manner that prevents theeffluent from reaching unfrozen receiving watersor a discharge to upland areas in a manner thatdoes not cause destruction of vegetation or anincrease in soil erosion). Wherever possible,discharge to dry channels, tundra, or uplandareas is preferred to discharge to surface waters(TAPS Owners 2001). The permit requires theAPSC to maintain a Storm Water PollutionPrevention Plan (SWPPP) for industrial activity,including excavation dewatering projects inexcess of 5 acres.

On December 27, 1996, the APSC submittedan application to the ADEC for a WastewaterDisposal Permit for a number of wastewatersgenerated at facilities located along the TAPS.At that time, the ADEC acknowledged it did nothave time to review the application and issue apermit in a timely manner. Consequently, itgranted APSC verbal authorization to dischargeall of the wastewater streams listed in the DraftWastewater Disposal Permit submitted with the

C-27 APPENDIX C

TABLE C-7 Discharges Addressed in the Linewide NPDES Permit for 1998a

Category Source Discharge Volume Discharge Point Treatment

Excavationdewatering

Maintenance of buriedpipeline

380 gal/d to21 million gal/d

Varies; uplanddischargepreferred

BMP, erosioncontrol, infiltration

Hydrostatictesting

Leak testing of new orrepaired pipelines andtankage

Varies − 1996/7:7,800,000 gal/yr

Dry channel,snow

BMP, erosioncontrol, infiltration

Sanitarywastewater

PS 5, 6 MCCFs 6,000 gal/d14,000 gal/d each

Tundra wetlands Secondarybiological

Tank farms 4,000,000 gal/yrValve vaults 500,000 gal/yrBasement 50,000 gal/yrLeading edge flow meters 30,000,000 gal/yr

Secondarycontainmentdewatering

Fuel loading areas 10,000 gal/yr

PS workpad BMP, sorbentused if sheennoted

Petroleum product spill 500,000 gal/yrPS air filter cleaning 20,000 gal/yrMonitoring well purging 100 gal/eventPump test water 300-900 gal/eventPS mop water 50,000 gal/yrPS meltwater 10,000 gal/yrPS equipment shopmeltwater

10,000 gal/yr

PS accumulated rainwater

1−500 gal/event

Potentiallycontaining oil

Vacuum truck hydrotest 25,000 gal/yr

Facility workpad BMP

Outdoor vehicles washing 10,000 gal/yr PS workpad BMPIndoor vehicles washing 10,000 gal/yr

Containingparticulate

Equipment/structurewashing

100−3,000 gal/event

Water truck disinfection 2,000−4,000 gal/event Facility workpad BMPContainingchlorine Drinking water facility

disinfection1−500 gal/event

APPENDIX C C-28

TABLE C-7 (Cont.)

Category Source Discharge Volume Discharge Point Treatment

Fire line flushing 100,000 gal/yr PS workpad BMPFire training 2,000 gal/yr

Containingresidual AFFF

Fire truck flushing 3,000 gal/event Airport taxiway

a Abbreviations: AFFF = aqueous-film-forming foam; BMP = best management practices; MCCF =mobile contingency camp facility; PS = pump station.

Source: TAPS Owners (2001).

application (Gryder-Boutet 1996). The permitcovers discharges from secondary containmentareas, waters potentially containing oil and/orsediments, petroleum product spill water (landdischarges only), waters containing chlorine,waters potentially containing aqueous film-forming foam (AFFF), and waters collected inactive cells of permitted solid waste disposalsites. The permit establishes effluent limitationsand monitoring requirements for eachwastewater stream, including limits on erosionand sediment accumulation, as well as totalaromatic hydrocarbons, total petroleumhydrocarbons, and total aqueous hydrocarbons.

The Valdez Marine Terminal also operates asanitary waste treatment plant (SWTP). SWTPeffluent discharges to permitted Outfall 002,which is located at latitude 61º 05�14� N andlongitude 146º 23�24� W. Effluent limitations areestablished for flow, biochemical oxygendemand (BOD5), TSS, and pH. The permitestablishes a mixing zone and effluentmonitoring requirements.

Table C-8 gives the SWTP effluent flowaverages in CY 2000. The total SWTP effluentflow for CY 2000 was 705,399 gal; the averagedaily flow was 1,932.6 gal.

The sanitary sewage system collects andtreats sewage generated at the Valdez MarineTerminal, including shower, sink, kitchen, andtoilet wastewater. Sewage generated at the mainonshore buildings is piped to the SWTP(Building 58-BD-6) via gravity-flow sanitarysewer pipelines. Holding tanks located atBerths 1, 3, 4, and 5, Area 19, and the BallastWater Treatment (BWT) Control Area collect

sewage generated in those buildings/areas. Avacuum tank truck periodically removes thesewage from the holding tanks and transports itto the SWTP.

The SWTP consists of a below-grade wetwell or sump tank, which is the final collectionpoint for all sanitary wastewaters generated on-site. The sump is equipped with lift pumps totransport wastewater to the influent end of thebiological treatment unit. The SWTP is apackage biological treatment unit consisting of askid-mounted, compartmentalized, steel tank

TABLE C-8 Sanitary WasteTreatment Plant EffluentFlow Averages for 2000

MonthVolume(gal/d)

January 2,644.0February 2,355.0March 2,274.0April 1,714.0May 1,635.0June 1,486.0July 1,611.0August 1,927.0September 1,724.0October 1,745.0November 1,999.0December 2,077.0Average daily flow 1,932.6

Source: APSC (2000d).

C-29 APPENDIX C

with pumps, blowers, and the electrical controlcircuitry. The unit has a rated hydraulic capacityof 10,000 gal/d (APSC 2000f).

The aeration basins do not discharge toeither the BWTF or the SWTP. Therefore, thesewastes are cleaned out periodically by acontractor and hauled to the City of Valdez underNon-Residential Wastewater Discharge Permit(City of Valdez 2001). The wastes aredischarged to Sewer Pump Station No. 1 at theCity of Valdez sewage treatment plant, includingsludges from the SWTP aerobic digester, ValdezMarine Terminal septic tanks, and variousValdez Marine Terminal and SERVS holdingtanks. Other APSC facilities discharge domesticsanitary wastewater directly to the City of Valdezsewage collection system. The SERVS bargewaste is also disposed of through the City ofValdez sewage treatment plant. A total of43,000 gal of sewage was discharged to the Cityof Valdez in 1999 (APSC 2000e). Of that,22,700 gal was attributable to the aerobicdigesters, 15,000 to the SWTP, and 5,300 toSERVS.

Domestic sanitary and industrial wastewaterfrom the Van Horn Facility is discharged toGolden Hearts Utilities pursuant to an IndustrialPre-Treatment Program Wastewater DischargePermit, effective November 24, 1999 (Noll 2001).Pretreatment of the wastewater from this facilityis accomplished with an oil/water separator.PS 5 is served by an extended aeration activatedsludge sewage treatment plant (STP), whichdischarges through a diffuse outfall acrosstundra wetlands (TAPS Owners 2001). Digestedsludge from the PS 5 treatment plant is collectedand hauled by a contractor for discharge directlyto the Golden Hearts Utilities facility sludgethickener unit. This discharge is permitted undera Special Discharge Permit, effectiveDecember 17, 2000 (Owen 2000).

As described in the Environmental Reportfor Trans Alaska Pipeline System Right-of-WayRenewal (TAPS Owners 2001), screeneddomestic sanitary wastewater from PS 1, 3, and4 is stored in a holding tank and then pumped tothe exhaust stacks of the engines powering thecrude oil pumps. High-pressure nozzles injectthe wastewater into the hot exhaust flow, whereit is atomized and dispersed into the atmosphereas sterilized water vapor. Screenings are

incinerated at each pump station. Periodically,holding tank sludges are cleaned out andtrucked away for disposal at municipalwastewater utilities, including North SlopeBorough, Fairbanks Municipal Utility System,and City of Valdez Sewage Treatment Plant(APSC 2000g). Since an extended aeration-activated sludge plant was installed at PS 6,stack injection technology is no longer utilized atthat station (Edwards 2002a; Mikkelson 1997).MCCF 2 and MCCF 3 have self-containedsanitary wastewater secondary treatmentsystems that use a rotating biological contractortechnology and a holding tank. Treatedwastewater from each site is discharged locallyin accordance with the linewide NPDES permit.(TAPS Owners 2001). Domestic sanitarywastewater from PS 7, 8, 9, 10, and 12 isdischarged to individual septic systems. ThePS 6 Fly Camp has a septic system, however,PS 6 is now using the personnel living quartersrather than the fly camp (Edwards 2002a). Thesesystems are periodically cleaned out by acontract service. Domestic sanitary wastewaterfrom the APSC office complex in Anchorage andin Fairbanks is connected to the municipalwastewater treatment systems. Typical flowsand design capacity for these systems areshown in Table C-9.

APSC has filed Notices of Intent (NOIs) tobe governed by the EPA Multi-Sector GeneralPermit for Industrial Activities for each of12 industrial areas affiliated with pipelineoperations, such as the operations materialsites. Each NOI includes a StormwaterCharacterization Checklist, which providesinformation on the site history, sitesetting/topography, precipitation and storm-water characterization, observed barriers tostorm-water flow reaching adjacent waterbodies, and adjacent water bodies/wetlands thatmay be impacted by the site (APSC 1999b). TheMulti-Sector General Permit authorizes storm-water discharges from certain types of industrialfacilities provided the permittee complies withthe conditions of the permit, including preparingand implementing a SWPPP. The SWPPPidentifies sources of potential pollutants thatcould contaminate storm-water discharge fromthe area and establishes BMP to minimize andcontrol these potential pollutant sources, such as

APPENDIX C C-30

TABLE C-9 Typical Effluent Flows of Sanitary Wastewaterat Various Sites in 1997

SiteCurrent Wastewater

DisposalTypical Flow

(gal/d)

DesignCapacity(gal/d)

PS 1 Stack injection 2,000 10,000PS 2 Stack injection (not in use) 4,00 (sic) 10,000

PS 3 Stack injection 7,500 10,000MCCF 2 Secondary biological 2,900 14,000PS 4 Stack injection 4,700 10,000PS 5 Secondary biological 6,300 8,000

PS 6b Stack injection (not in use) 6,500 6,000

Fly Camp atPS 6c

Septic 950 850

PS 7 Septic 3,800 3,400PS 8 Septic 600 1,000PS 9 Septic 780 1,000PS 10 Septic 4,200 12,000MCCF 3 Secondary biological 3,500 14,000PS 11 NAa NA NA

PS 12 Septic 4,200 9,100

a NA = data not available.

b PS 6 is now using a self-contained biological wastewater treatmentsystem.

c PS 6 is now using the pump station living quarters rather than the FlyCamp (Sweeney 2002).

Sources: Mikkelsen (1997); TAPS Owners (2001).

preventive maintenance, good housekeeping,and sediment and erosion control.

As needed, the APSC files NOIs to begoverned by the EPA General Permit forDischarges from Construction Activities. Thispermit allows discharge of storm-water runofffrom construction sites in excess of 5 acres if thepermittee complies with the conditions of thepermit. This permit may not be used if the storm-water discharges are not protective of federallisted endangered and threatened species ordesignated critical habitat. A SWPPP must bedeveloped for each construction site, including

the identification of pollutant sources andmitigation actions to prevent contamination ofstorm water runoff. A Notice of Termination mustbe filed within 30 days of the final stabilization ofthe site.

C.6 Special Wastes

Special handling procedures have beenestablished for numerous other wastesassociated with TAPS operations. Wastesdiscussed under this category include wastes forwhich specific regulatory controls exist, wastes

C-31 APPENDIX C

that are routinely generated, wastes for whichunique management and disposal schemeshave been established, and wastes that have ahigh potential for adversely affecting theenvironment or human health if not managedproperly. TAPS special wastes includepolychlorinated biphenyl (PCB) wastes,asbestos wastes, pesticide wastes, dragreducing agent wastes, spent glycols, tankergarbage, medical wastes, spent sandblastmedia, asphalt, radioactive wastes, naturallyoccurring radioactive materials (NORM) wastes,and spill debris and remediation wastes.

C.6.1 Polychlorinated BiphenylWastes

PCBs are known to be present in someAPSC equipment at pump stations, maintenancefacilities, and the Valdez Marine Terminal. Aninitial systemwide survey for PCB-containingitems was conducted in 1989. Equipment andsystems surveyed included electrical equipment,such as transformers, capacitors, relays,electrical actuators, and switches. Both in-service and stored equipment were included inthe survey. In addition, fluorescent lightingfixtures that are not expressly labeled by themanufacturer as PCB-free were presumed tohave PCBs present in their ballasts. Hydraulicsystems and equipment containing heat transferfluids were also surveyed and characterized. Asecond verification survey was conducted in1995 (EMCON Alaska, Inc., 1995). Surveytechniques included physical inspections,reviews of equipment nameplate information andproduct specifications, interviews withequipment or product manufacturers, interviewswith maintenance supervisors, and reviews ofmaintenance records. In some instances,suspect fluids (e.g., dielectric oils, heat transferoils, etc.) were sampled and analyzed for thepresence of PCBs in regulated concentrations.

Together, the two surveys established thefollowing with respect to the presence of PCBs inTAPS facilities.

• Capacitors in solid-state controls in the staticinverter system at the North Pole meteringstation contain PCBs. These capacitorsmeet the definition of �small capacitor�

contained in EPA regulations (40 CFR761.3(1)). They are located within a buildingthat provides adequate containment of anyspills or leaks and are expected to continuein service until the ends of their useful lives.

• Twelve large capacitors in service at theValdez Marine Terminal are assumed tocontain PCBs in concentrations below50 ppm. All capacitors are located withinrestricted access areas inside buildings thatprovide adequate containment of any spillsor leaks. All capacitors are properly labeledas �PCB Articles� and are expected tocontinue in service until the ends of theiruseful lives.

As a matter of APSC policy, capacitorspresent in the ballasts of some fluorescentlighting fixtures throughout the APSC arepresumed to contain PCBs unless explicitlylabeled to the contrary by the manufacturer.These fixtures will stay in service until the endsof their useful lives. At that point, the ballasts willbe removed and managed through the APSChazardous waste contractor.

The PCB inventories suggest that there isthe potential for only very small amounts of PCBwastes to be generated. Such wastes will resultwhen PCB-containing electrical equipment istaken out of service or in response to a spill orleak from operating equipment. The surveys alsoconfirmed that the operating locations for allPCB-containing equipment satisfy EPArequirements for containment of any spills orleaks from such equipment. APSC procedurescall for all disposals of equipment that containsor may contain PCBs to be coordinated throughAPSC environmental authorities. Althoughcertain PCB-containing articles can be disposedof in municipal landfills in accordance with EPAregulations, APSC policies require that PCBwaste be handled through the APSC hazardouswaste contractor and disposed of in facilitiesspecifically permitted for PCB wastes.

C.6.2 Asbestos Wastes

Asbestos-containing materials (ACMs) areknown to be present at APSC pump stations andthe Valdez Marine Terminal. Surveys by APSC�sindustrial hygienists revealed that ACM is

APPENDIX C C-32

present in some infrastructure components(building materials) and some components ofpipeline equipment (Norton 2001a). APSC�s FireSafety and Industrial Hygiene (FSIH) personnelare in the process of developing a formalsystemwide asbestos management plan,expected to be available in early 2002. Despitethe lack of a formal plan, however, other controlsare in place to ensure timely identification ofACM and proper management of ACM wastes.Each APSC industrial hygienist maintains aninventory of ACM in facilities for which they areresponsible and periodically inspects theirfacilities to verify that ACM is not damaged ordeteriorated to a degree where the release ofasbestos fibers to the air is possible. Wheneverinfrastructure or equipment maintenance, repair,or refurbishment has the potential to disturbACM (including asbestos abatement actionssuch as the planned removal of deterioratedACM), FSIH personnel reviewing the plannedactivities will intervene and impose specialcontrols to ensure proper isolation of ACM. TheAPSC Safety Manual SA-38, Requirement 1.26,requires that such reviews be incorporated intowork plans.

APSC maintenance employees areresponsible for removing and replacing ACMitems such as gaskets. Such simple replacementactivities are not considered by OSHA to beasbestos abatement and are performed byAPSC maintenance personnel. Wastesgenerated from such simple maintenanceactivities are nevertheless identified ascontaining asbestos. The ACM wastes aredelivered to one of the Alaska municipal landfillsor disposed of through the hazardous wastecontractor facilities. Currently, the municipallandfills at Palmer and Anchorage, as well as theSouth Cushman landfill in Fairbanks, areauthorized by ADEC to receive asbestos wastes.All three landfills have received ACM wastesfrom the APSC. When infrastructuremaintenance, repair, or remodeling impactsACM present in building components, speciallylicensed contractors will remove and properlycontainerize the ACM. APSC environmental staffmake advanced disposal arrangements for anyACM waste and are responsible for making anynecessary notifications to the EPA for suchremoval and disposal events.

C.6.3 Pesticide Wastes

Only very small amounts of pesticides areused to maintain the pipeline ROW and otherAPSC facilities. With the exception of personalprotection products (e.g., mosquito repellant),each chemical to be used and its applicationrestraint must be approved by the AuthorizedOfficer (Stipulation 2.2.5.1). In most instances,commercial, licensed applicators are used whenpesticide applications are necessary. Thosecontractors are responsible for using thepesticide in the manner prescribed by the labeland in engaging in practices that will minimizethe amounts of pesticide wastes needingdisposal. When necessary, disposal of pesticidewaste is controlled by federal hazardous wasteregulations as a Universal Waste. Disposal ofpesticide waste occurs at out of state RCRATSDFs.

C.6.4 Drag Reducing AgentWastes

Drag reducing agent is injected into thepipeline at various pump stations to reduceturbulence and enhance laminar flow in thepipeline, thus reducing the amount ofhorsepower needed to pump crude oil. A numberof different commercial formulations are used.Drag reducing agent is a proprietary mixture ofolefinic long-chained petroleum distillates withflash points in the range of 105° to 131°F. Undernormal conditions, drag reducing agent willcomingle with the crude oil and undergomolecular changes resulting from mechanicalactions of turbine impellers. It does not need tobe removed from the oil when it reaches theValdez Marine Terminal. The APSC hasestablished specific controls for managing dragreducing agent wastes that result fromaccidental spills or releases at its points of use.Waste drag reducing agent and spill debris(including rags and absorbent pads) arecontainerized in vapor-tight fiber drums or clearplastic bags and stored in designated hazardouswaste storage areas. Small amounts (less than½ gal) are incinerated at APSC facilities. Largeramounts are handled by the APSC hazardouswaste contractor and delivered to designatedfacilities where it is burned as supplemental fuel.

C-33 APPENDIX C

C.6.5 Spent Glycols

Glycols are used as antifreezes andcoolants and as rust inhibitors in a variety ofAPSC equipment. Ethylene glycol, propyleneglycol, and triethylene glycol wastes aregenerated primarily at pump stations and theValdez Marine Terminal, as well as at thecontractor facility where APSC vehicles aremaintained. APSC procedures prohibit theincinerating or placing any waste glycol intolandfills. All waste glycols are stored indesignated waste storage areas until they areremoved by the APSC waste contractor.Currently, all waste glycols are delivered to arecycling facility.

C.6.6 Tanker Garbage

Separate management procedures are inplace for putrescible solid wastes from tankersfrom Hawaii and foreign ports that berth at theValdez Marine Terminal. In accordance withU.S. Coast Guard and USDA Animal and PlantHealth Inspection Service regulations, garbagefrom tankers is considered �regulated garbage�and is treated as potentially infectious waste.Wastes are collected in red bags, designated asregulated garbage, and delivered to acommercial facility in Anchorage where thewaste is sterilized by autoclaving. Sterilizedwastes are subsequently delivered to theAnchorage municipal landfill by the sterilizationcontractor.

C.6.7 Medical Waste

Separate management procedures are inplace for medical waste generated throughoutthe TAPS at clinics and first aid stations. Out-of-date medical products that exhibit thecharacteristics of ignitable or toxic hazardouswaste are managed as hazardous waste.Medical supplies that are nonhazardous aremanaged as solid wastes and, depending on thepoints of generation, sent directly to the landfillserving that facility or to one of the APSCincinerators.

Very limited amounts of medical waste thatmay be biohazardous or infectious(i.e., containing blood, tissue, or blood-bornepathogens) are incinerated at APSCincinerators. The APSC conforms to therequirements of 40 CFR Part 60, Subpart E, forsuch incineration, including notification, recordkeeping, and reporting. The APSC incineratorsare also covered by air emission permits issuedfor each pump station and the Valdez MarineTerminal by the ADEC. However, the latestiterations of those permits require the APSC tomaintain records of amounts of wastes burned ineach incinerator, but these have been modifiedto remove previous record-keeping requirementswith respect to amounts of medical wasteincinerated (ADEC 1996). Nevertheless, theAPSC continues to maintain such data.Table C-10 provides data on amounts of medical

TABLE C-10 Amounts of Medical Wastes and Solid Wastes Burnedin APSC Incinerators in 2000a

Incinerator Locationb

Total SolidWaste

Incinerated (lb)Medical WasteIncinerated (lb)

% of MedicalWaste to Total

Waste Incinerated

PS 1 69,975 0 0PS 3 305,290 86 0.028PS 5 154,953 55 0.036PS 7 105,128 0 0PS 12 17,716 0 0Valdez Marine Terminal 82,720 53 0.064Total 735,782 194 0.026 (average)

a Data provided by APSC (Seward 2001b).

b Incinerators at PS 2, 4, 6, and 10 were not operational during CY 2000.

APPENDIX C C-34

wastes and solid wastes burned in the pumpstation incinerators during CY 2000. Dataprovided for the first two quarters of 2001indicate that rates of medical waste and solidwaste incineration have not changedsignificantly from 2000 (Seward 2001b).

C.6.8 Spent Sandblast Media

Spent sandblast media wastes aregenerated as the result of a number of repair andrefurbishment activities as well as part ofcorrosion control activities. Wastes aregenerated under controlled conditions atmaintenance facilities or pump stations and arealso generated under uncontrolled conditionsalong the ROW in connection with maintenanceor repair activities, corrosion control activities, orspecial projects such as technologyenhancements or control valve vaulting.Sandblasting media are normally GreenDiamond or red garnet sand. Manufacturers ofthe Green Diamond sand have providedinformation that demonstrates that the sand doesnot contain leachable heavy metals that wouldcause the spent sand to become hazardouswaste (Glenbrook Nickel Co., undated). Aninternal APSC memorandum confirms that thered garnet sand is similarly inert (Redmond1994). Spent sandblast media becomecontaminated with pieces of the coatings presenton the equipment or surfaces being sandblasted.APSC�s routine analyses of spent media haveconsistently demonstrated that spent mediadoes not exhibit characteristics of hazardouswaste.

Data were provided to the ADEC in 1995,along with a request for approval to use spentmedia that do not exhibit characteristics ofhazardous waste as fill, rather than discardingthem as waste (Morton 1995; Lipchak 1995).The ADEC has concurred in this practice,provided the APSC continues to document thenonhazardous nature of spent media withappropriate analyses (Chapple 1995).Consequently, spent media generated incontrolled conditions are collected, analyzed toconfirm their nonhazardous character, andstored for later use as fill material. When spentmedia waste can be anticipated in ROWactivities where its collection is difficult to control

use, the coating being removed is evaluated forthe presence of heavy metals that would causespent media to exhibit hazardous wastecharacteristics. When no such heavy metals areknown to be present in the coating to beremoved, spent media are allowed to remain atthe job site (e.g., in the excavation). All analyticalresults are retained as part of the documentationfor each specific ROW project. No precisevolumes of spent media are available. However,internal APSC memoranda suggest that mostROW projects result in the use of anywhere from25 to 100 lb of media (Redmond 1994).

C.6.9 Asphalt

Waste asphalt paving is periodicallygenerated as a result of workpad maintenance orthe removal of tank aprons and parking areas. In1995, the APSC explored options for reuse andrecycling of this material with the ADEC (Morton1995; Lipchak 1995). The ADEC has approvedthe reuse of spent asphalt as constructionbackfill, road/pad base and bedding for tanks,pipes, and conduit. However, although theasphalt is weathered, it still may have somepotential to leach petroleum hydrocarbons.Consequently, the ADEC has limited use ofasphalt as bank stabilization material incircumstances where it may come into contactwith surface water (Chapple 1995). No volumesof waste asphalt being reused are available.

C.6.10 Radioactive Wastes

Small amounts of radioactive wastes arepossible from the operation and maintenance ofTAPS facilities. These include discarded smokedetectors that contain americium and self-illuminated EXIT signs that contain smallamounts of tritium. Both the radioisotope and itsconcentration dictate the disposal path for suchmaterials. Wastes containing radioactivematerials are segregated from other solidwastes, containerized, and given two labels:�nonhazardous waste� and �radioactive waste.�Containers of spent EXIT signs are stored indesignated hazardous waste storage areas andsubject to the same routine inspections forcontainer integrity as hazardous wastecontainers. Spent EXIT signs are ultimately

C-35 APPENDIX C

shipped by the TAPS facility at which they weregenerated to the manufacturer for recycling. TheWaste Management Specialist arranges for thelights to be shipped to a recycler for recoveryand reprocessing of the tritium. Smoke detectorsare containerized and shipped back to themanufacturer for disposal. Facilities at whichspent smoke detectors are generated areresponsible for ensuring that the detectors arenot incinerated or sent to any of the APSC-operated landfills. Otherwise, the smokedetectors are placed in landfills.

C.6.11 Naturally OccurringRadioactive Material(NORM)

Radioactive isotopes of uranium and thorium(and their respective progenies) are known to bepresent in rock formations from which NorthSlope oil is recovered. These naturally occurringradioisotopes dissolve in formation water andare brought to the surface along with oil and gasrecovered from the formation. NORM waste isgenerated as the result of the precipitation ofthese isotopic salts onto the inside surfaces ofwell pipes (tubulars) as well the surfaces ofvarious �downhole� equipment such as safetyvalves and gas mandels.

Radioisotopes are present only in theaqueous phase of materials brought to thesurface during oil exploration and recovery.Because the TAPS has established rigorouscriteria limiting the amount of water allowed tobe present in oil accepted at PS 1, the potentialis very low for NORM waste issues to bemanifested in pipeline or marine terminaloperations. A memoranda from British Petroleum(BP) to the APSC confirms that NORM wastesare associated primarily with the water fractionsand that since production water and sedimentsfrom aboveground production vessels areremoved before oil is delivered to PS 1 formetering and introduction into the pipeline, theamount of NORM waste entering the pipeline isnegligible (Taylor 2001a).

APSC FSIH personnel have conductedsurveys of selected TAPS facilities for thepresence of NORM in 1991, 1993, and 1994.Survey locations were places where water and

condensate could accumulate and whereprecipitation of dissolved salts might occur. Theyincluded rust and scale in crude oil Tank 111(PS 1), tank bottoms from Tanks 16 and 17(Valdez Marine Terminal), heat exchangerbundles at PS 6 and the Desalter at PS 10. Noneof these surveys detected NORM abovebackground levels (APSC 2001c).

Currently, the APSC is engaged in awholesale removal of tank bottoms, rust, scale,and other sediments from crude oil storage tanksat the Valdez Marine Terminal. NORM surveysare being conducted on the tank bottoms as theyare being removed from the tanks and oncondensate withdrawal plumbing inside the tank.Surveys completed to date for Tank 5 indicatedno NORM to be present above backgroundlevels in tank bottoms or on the inside surface ofthe condensate withdrawal line. In addition,surveys conducted on the soles of workers�shoes as they exited the tank also showed noNORM contamination. Valdez Marine TerminalIndustrial Hygiene personnel intend to samplethe rust and scale on the inside tank walls whenthe removal of tank bottoms is completed(Norton 2001b). Because the tank bottoms havebeen accumulating over a long period of time,the materials and areas surveyed during the tankcleanout operation are considered to represent a�worst case� with respect to NORMcontamination. The data appear to indicate,therefore, that significant amounts of NORMwastes are not associated with routine pipelineoperations.

C.6.12 Spill Debris andRemediation Waste

Section 6, Waste Management, of the TAPSEnvironmental Protection Manual, EN-43-2,provides detailed guidance on the managementof wastes resulting from accidental releases ofcrude oil, refined petroleum product, orhazardous materials (APSC 2000b). Wastesmay result from the initial response to a releaseand also as a result of subsequent remediationof affected environmental media. Ultimate spillsite remediation and restoration are subject tocase-by-case approval of JPO agencies.Nevertheless, the APSC has an obligation tocorrectly manage all wastes resulting from the

APPENDIX C C-36

release event within the context of the approvedremediation/restoration plan. Specific guidancehas been developed for spill debris includingcontaminated rags, sorbents, and personalprotective equipment (PPE), as well as forcontaminated environmental media (soil,including gravel that makes up the pipelineworkpad or backfill materials associated withburied pipeline segments, surface water, andgroundwater). For the purpose of this discussion,contaminated soils include natural materialssuch as soils, subsoils, or gravel that have beencontaminated with crude oil, refined petroleumproducts such as gasoline, diesel fuel andturbine fuel, lubricating oils, hydraulic oils,sludge contained in pipeline storage tanks orequipment, or petroleum-based heat transferfluids. Section 3.16.4 provides information on themanagement of petroleum-contaminated waters.

In general, the management of all spilldebris and contaminated media first involvestheir characterization as hazardous ornonhazardous wastes. This is carried out by theapplication of circumstantial factors (e.g., thematerial spilled), or as the result of sampling andanalyses when process knowledge is insufficientto support a complete waste evaluation. Wastedetermined to be hazardous is incorporated intothe existing hazardous waste managementprogram as dictated by logistics of the spill.Waste determined to be nonhazardous is furtherevaluated against the ADEC soil cleanup levelscontained in state regulations (see 18 AAC75.341). Case-by-case decisions are maderegarding the management of nonhazardouswastes after this evaluation is completed.Options include incineration at the nearest PS,in-situ remediation through the application ofsuch technologies as biological treatment or soilventing (if approved by JPO authorities),stockpiling for later thermal treatment orplacement in APSC-operated or municipallandfills. Soil that contains hazardoussubstances in concentrations exceeding one ormore of the applicable �migration togroundwater� levels prescribed in stateregulations, exhibits a characteristic of toxicitydefined in 40 CFR 261.24(a), or is determined bythe ADEC to pose a threat of migration (ofhazardous constituents) to surface water isprohibited from disposal in any of the APSClandfills. Acceptance criteria have been

established for petroleum-contaminated soils atall of the municipal landfills that currently acceptAPSC solid wastes.

Finally, within the context of the approvedremediation and restoration plan for each spillevent, special provisions may also be includedfor the interim storage of spill debris orcontaminated media at or near the spill site, atthe nearest pump station, or at the ValdezMarine Terminal. Storage that is incident to the�immediate response action� is approved byADEC authorities overseeing response actions.Normally, such immediate storage or stockpilinglasts for 30 days or less. Storage for longerperiods of time may also be approved; however,�short-term stockpiling� or �long-term stockpiling�plans must be developed and submitted to theADEC for approval. The APSC has obtainedpreapproval from ADEC to construct long-termstockpiles at some pump stations and the ValdezMarine Terminal. Pump station stockpiles can bemaintained for up to two years. Those at theValdez Marine Terminal are authorized for up tofour years. In both instances, volume limits arealso specified in the approved stockpiling plans.These approaches incorporate the designspecifications and operational control for soilstockpiles contained in APSC�s linewide soilstockpile management plan (APSC 1999a).

In recent years, contaminated soils havebeen stockpiled at PS 1, 2, 3, 4, and 9, at ControlValves 10 and 12, and at the Valdez MarineTerminal (APSC 2001d; Schmidt 2000;Schnabl 1996; Clearwater/Golder J.V. 2000; OITInc. 1999, 2001a,b). Soils and other debris fromresponses to accidental releases remain in theADEC-approved stockpiles until the maximumauthorized volumes or storage time limits arereached, or until sufficient volumes have beenaggregated to allow for cost-effective transportand treatment. All stockpiled contaminated soilsare ultimately removed by a transport contractorand delivered under a �Contaminated Soils(Non-Hazardous) Custody Transfer� form to asubcontractor for thermal treatment. Mostrecently, a contractor located in North Pole,Alaska, has been utilized (Schmidt 2000;Schnabl 1996; Clearwater/Golder J.V. 2000).The treatment contractor conducts treatmentunder the auspices of an air emissions permitissued by the ADEC. The treatment contractor

C-37 APPENDIX C

____________________________

2 Contaminated soils from Toolik were approximately 58 tons (Guthier 2002).

also subjects treated media to analytical testingto verify successful treatment to contaminantlevels below those specified in ADECregulations. Other contaminated items related tosoil stockpiling, such as liners and covers, aremanaged in the same manner.

In 1999, 2,302.23 tons of stockpiled soilsfrom PS 1, 2, 3, and 4 and from Check Valves 10and 12 were delivered for thermal treatment.This total represents contaminated soilsresulting from spills along the ROW and at thepump stations over an approximate two-yearperiod. Also included in this total arecontaminated soils removed during remediationof historic releases at the Toolik Work Camp.2

Table C-11 gives the amounts of contaminatedsoils that have been stockpiled at the ValdezMarine Terminal since 1996.

Acceptable levels of treatment are specifiedin ADEC regulations and are specific to materialspilled, potential for migration, potentialreceptors, and various other site-specificparameters. Treatment levels appear in ADECregulations at 18 ACC 75.325 through 75.390.These levels define the allowable residual levelsof specific chemical constituents that will beallowed to remain at the location where arelease has occurred. The thermal treatmentcontractor�s analyses of treated soils arereferenced against these allowable residuallevels, providing maximum flexibility formanagement of treated soils. Options fordisposition of successfully treated soils includereturning them to the spill location, sending themto a landfill to be used as clean cover material,or using them in other circumstances as fill.

C.7 Cumulative Waste

C.7.1 Wastes Associated withCumulative Factors

Waste impacts can be associated with manyof the past, present, and reasonably foreseeableactivities that qualify as cumulative impacts. Inmost instances, the majority of waste impactsassociated with those activities are generallyrelated to human habitation or presence (i.e., thegeneration of domestic solid wastes and

TABLE C-11 Contaminated SoilStockpiled at the Valdez MarineTerminala

YearVolume(yd3)b

Weight(tons)c

1996d 131.9 237.41997 607.9 1,094.21998 168.2 302.81999 208.5 375.32000 670.2 1,206.42001 867.7 1,561.9

a Soils stockpiled at the Valdez MarineTerminal result from response to, andremediation of, releases at the ValdezMarine Terminal as well as along theROW at such locations where it wasfeasible to transport contaminated soilfrom the spill site to the Valdez MarineTerminal for stockpiling.

b All volumes are approximate.

c The weight of a cubic yard ofcontaminated soil will vary greatly,depending on such parameters as soiltype, percent moisture, and extent ofcontamination. For the purpose of thistable, one cubic yard of contaminatedsoil is assumed to weigh 1.8 tons.This number was empirically derivedby comparing weights of soils fromeach APSC stockpile locationundergoing thermal treatment (asreported by the treatment contractor)to estimated yardages of soilsremoved from those same APSCstockpile locations (as provided by thetransport contractor).

d Volume and weight displayedrepresent soils stockpiled fromSeptember 25, 1996, to December 31,1996. On September 25, 1996,2,172.9 yd3 of contaminated soilsfrom the Valdez Marine Terminalstockpile underwent thermaltreatment, bringing the stockpiledvolume of contaminated soils at theValdez Marine Terminal to zero.

Source: APSC (2001d).

APPENDIX C C-38

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3 The SIC codes were developed by the federal Office of Management and Budget (OMB) to track the flow ofgoods and services within the economy. The OMB has recently devised a different industry categorizationsystem, the North American Industry Classification System (NAICS). A complete list of SIC codes andconversions between SIC and NAICS categories is available on the Internet at http://www.census.gov/epcd/www/naics.html. There are five major groups within SIC 13: (1) SIC 1311 Crude Petroleum and Natural Gas,(2) SIC 1321 Natural Gas Liquids, (3) SIC 1381 Drilling Oil and Gas Wells, (4) SIC 1382 Oil and Gas FieldExploration Services, and (5) SIC 1389 Oil and Gas Field Services Not Otherwise Classified.

domestic and sanitary wastewaters). With theexception of North Slope activities, humanhabitation related to these cumulative actions(i.e., the workforce engaged in those actions)would likely occur at or near population centersor established communities. It is thereforeassumed that solid wastes and domestic andsanitary wastewaters attributable to thatworkforce would be managed in existingmunicipal treatment or disposal facilities. It isfurther assumed that the relative sizes of theworkforces engaged in most cumulative actionsare small relative to the sizes of the communitiesin which they reside or work, and that cumulativeactions would have only incremental impacts onexisting waste management systems.Consequently, those waste impacts are notanalyzed further. Such assumptions are onlypartially correct for the North Slope; thus, wasteimpacts from the presence of a workforce at theNorth Slope are included in this analysis. Amongthe potential cumulative actions identified inTable 4.7.4-1, three ongoing actions havesubstantial waste impacts: (1) North Slope oilexploration, development, and production(including maintaining the North Slopeworkforce); (2) oil refining at three of the fouroperating refineries in Alaska; and (3) tankerloading activities at the Valdez Marine Terminal.One proposed action, the construction of anatural gas pipeline also has the potential forsubstantial waste impacts.

C.7.2 Hazardous Materials andWastes Associated withOil Exploration,Development, andProduction

The volumes and chemical characteristics ofwastes associated with oil exploration,development, and production are heavilydependent on the characteristics of the oil-bearing formation from which the oil is extractedand the extraction techniques employed.

However, some general similarities exist. InOctober 2000, the EPA published acomprehensive profile of the oil and gasextraction industry (EPA 2000). The profilecovered all major activities within the StandardIndustrial Classification (SIC) 13.3 Unlessotherwise referenced, the generic descriptions ofwastes and waste management options providedbelow were derived from that EPA publication.

Mixtures of oil, production water, and naturalgas are recovered from each onshore well at theNorth Slope and sent without separation to acentral processing facility where separation ofoil, water, and natural gas is accomplished.Similar mixtures recovered from offshoreproduction wells undergo initial separation atthose offshore facilities before being sent tonatural gas pipelines or the TAPS, or managedas wastes.

C.7.2.1 Hazardous MaterialUsage in North SlopeOil Exploration,Development, andProduction

Only a limited variety of hazardousmaterials are used in oil exploration,development, and production. Relatively smallvolumes of chemicals may be used as additivesto facilitate drilling or to enhance the capability ofthe well to recover hydrocarbons. For example,mineral acids (primarily, hydrochloric acid andhydrofluoric acid) may be added to increasepermeability of the rock in the oil-bearingformation ( a process sometimes referred to asstimulation) or to stem the buildup of salts ondownhole equipment. Biocides may beintroduced to the well to inhibit the growth ofsulfide-loving bacteria, the growth of which isenhanced when air is introduced into the sulfide-rich environment that often exists in oil-bearingformations. Refined petroleum fuels andlubricants are also used to power the well drillingand recovery equipment.

C-39 APPENDIX C

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4 Underground injection control (UIC) wells are authorized by the Safe Drinking Water Act (SDWA). Class II UICwells are wells that inject fluids that are brought to the surface in connection with natural gas storage operationsor conventional oil or natural gas production and may be commingled with wastewaters from gas plants that arean integral part of production operations, unless those waters are classified as hazardous waste at the time ofinjection (see 40 CFR 144.6). In Alaska, the Alaska Oil and Gas Conservation Commission (AOGCC) has beengranted primacy for regulation of Class II UIC wells (see 40 CFR Part 145).

C.7.2.2 Wastes Generated during Oil Exploration, Development, and Production

Drilling fluids, produced waters, and otherwastes associated with the exploration,development, or production of crude oil, naturalgas, or geothermal energy are not hazardouswastes under RCRA (40 CFR 261.4(b)(5)). Anywastes that do not meet these criteria(e.g., generated from support facilities ormaintenance activities), that demonstrate ahazardous characteristic, or that are listed underRCRA as hazardous wastes, would have to bemanaged as RCRA hazardous wastes. BritishPetroleum Exploration (Alaska), Inc. (BPXA) andPhillips Alaska, Inc. (PAI) have jointly developeda waste management certification program forstaff and contractors. Training covers basicregulations, waste classification, facilityrestrictions, and paperwork requirements. BPXAdeveloped the Alaska Waste Disposal & ReuseGuide to provide consistent waste managementguidance to field personnel. This guide has beenadopted by PAI, and is followed by bothcompanies (BPXA 2001).

Well Drilling Wastes. Wastesgenerated during well drilling and completioninclude rock cuttings and drilling muds broughtto the surface. Drilling muds are solutions ofnatural or man-made materials introduced as aslurry to reduce friction during drilling and can beeither water- or oil-based. The volume of cuttingsgenerated is primarily a function of the depth anddiameter of the well being drilled and can rangeanywhere from 0.2 to 2.0 bbl per vertical foot ofwell.

Disposal of drilling muds and cuttings can beproblematic not only because of their potentiallylarge volumes, but also because of the potentialpresence of trace contaminants, includingmercury, cadmium, arsenic, and hydrocarbons.

These contaminants are present in the naturalmaterials from which the muds are made andalso in the oil-bearing rock formations. Acidicaqueous wastes may also be generated duringwell installation if acid is introduced to controlthe buildup of scale.

Production Wastes. By far, the largestvolume by-product of oil extraction is water thatis removed from the formation together with theoil. In wells nearing the ends of their productivelives, water can make up 98% of the materialbrought to the surface. Water production ratescan be as high as 8 barrels for every barrel of oilextracted. Although phase separation of oil andwater fractions recovered from each well iseasily accomplished, many of the hydrocarbonsand trace metal contaminants present in the oil-bearing formation will be water soluble.Inorganic contaminants in production water caninclude chlorides and carbonates of sodium,calcium, magnesium, potassium, lead, arsenic,barium antimony, and zinc, and various sulfurcompounds, including elemental sulfur andhydrogen sulfide. Organic contaminantsroutinely include benzene, naphthalene, toluene,phenanthrene, bromodichloromethane, andpentachlorophenol. Radionuclides can also bepresent in production waters as a result of thenaturally occurring presence of uranium andthorium and their respective radioactive decayproducts in the oil-bearing formation. Additionaldiscussions on oil field wastes containingradionuclide contaminants, often referred to asnaturally occurring radioactive material (NORM)wastes, are presented below.

Underground Injection Wells. Welldrilling wastes and production wastes on theNorth Slope are generally disposed of viaunderground injection. Class I disposal wells areregulated by the EPA.4 On the North Slope,Class I wells are approved only fornonhazardous and RCRA-exempt wastes, such

APPENDIX C C-40

as produced fluids, nonhazardous chemicals,meltwater pumped from impoundments, andresidues form spill cleanups. Some North Slopefacilities also use Class I wells to inject treatedsanitary and domestic waste. Class II disposalwells are regulated by the Alaska Oil and GasConservation Commission (AOGCC) and areused for waste that has come to the surfaceduring the production of oil, and gas, including,produced fluids, cuttings, and drilling muds thathave circulated in the well. Up to 8,000 bbl ofmuds and cuttings are generated per wellinstallation. In the past on the North Slope, mudsand cuttings were placed in surfaceimpoundments; now, however, the cuttings fromthe upper portion of a well are washed and usedas construction gravel for roads and pads, aftermeeting the state reuse criteria. The remainingcuttings are ground to a fine slurry in an on-sitegrind and inject plant and reinjected to anunderground injection well (BPXA 2001).

Other wastes approved for Class II disposalinclude water that collects in well cellars andfluids used to protect wells and process linesfrom freezing. Class II recovery wells injectapproved fluids directly into the oil-producingformation to maintain reservoir pressure andsweep residual oil from pore spaces in the rock.This process, known as enhanced oil recovery,is regulated by the AOGCC (BPXA 2001). TheAOGCC also regulates injection ofnonhazardous drilling wastes into the annulus ofan oil or gas well. This process, called theAnnular Disposal Program, is consideredincidental to drilling and not subject to regulation

under the underground injection control (UIC)program (Alaska Oil and Gas Association 2001).

Table C-12 shows the number of wells andbarrels of fluid injected to date for disposalpurposes for North Slope activities (Alaska Oiland Gas Association 2001).

C.7.2.3 Other WastesAssociated with NorthSlope Activities

Other wastes generated in association withNorth Slope oil exploration, development, andproduction include tank bottoms that result fromthe settling in of transfer lines and separationand processing equipment of solids suspendedin liquids brought to the surface in the productionwells, and a variety of wastes associated withwell maintenance, including NORM wastes.Some wastes also result from the operation ofthe central gas separation facility and theoperation and maintenance of housing facilities.

Gas Separation Facility. Materialsretrieved from each onshore production well(production water, oil, and gas) are deliveredwithout separation to the North Slope centralprocessing facility (also known as the GatheringFacility) for separation of the various fractions.Similar initial separations of crude oil, productionwater, and gas are performed at the offshorefacilities. Crude oil is delivered from theGathering Facility to PS 1 of the TAPS, where it

TABLE C-12 North Slope Injection Wells

Type ofInjection Well Number of Wells

Type ofWaste Fluid

Volume of WasteFluid Injected

(bbl)

Class II Disposal 21 Produced water (E&Pa exempt) 1.5 billion

Class II Disposal 8 Muds/cuttings and associatedE&P exempt wastes

70 million

Class I Industrial 6 Nonexempt, nonhazardous, andexempt E&P wastes

13 million

a E&P = exploration and production.

C-41 APPENDIX C

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5 Despite the name commonly assigned to this waste stream, there are no crude oil �storage� tanks on the NorthSlope. However, separation of the recovered fractions involves the use of various flow-through or surge tanksfrom which tank bottoms are typically recovered.

6 The Oxbow Landfill is a Class I landfill permitted by the ADEC to accept nonhazardous industrial solid wastes anddomestic solid wastes from North Slope activities. Class I landfills are defined in ADEC regulations as facilitiesthat accept for disposal 20 tons or more of municipal solid waste daily, based on an annual average (see 18 AAC60.300).

7 Downhole equipment includes safety valves, gas lift mandrills, downhole pumps, and production well tubulars(casings).

is analyzed, categorized as to its quality, andmetered into the TAPS pipeline. Productionwaters are returned to the wellhead forre-injection or to the Class II injection well fordisposal. Natural gas undergoes dehydration or�sweetening� before being sent to the fuel gaspipeline or is disposed of by incineration in aflare stack. (Flaring of natural gas may alsooccur at the wellhead when necessary tomaintain safe working conditions.) Sweeteningroutinely involves reacting the gas with a glycol(typically, triethylene glycol) that acts as adesiccant. Glycols can be recycled and reused,but ultimately, would need to be disposed of.Because no disposal facility exists on the NorthSlope that can properly handle spent glycol, thiswaste is shipped off-site for proper treatment ordisposal. Other wastes related to gassweetening such as molecular sieves, recoveredsulfur, or spent amine solutions (also used toremove water) may also be generated. All suchwastes would be sent to off-site treatment ordisposal facilities.

Tank Bottoms. Sands and otherinsoluble particulates that settle from productionwaters and oil brought to the surface will collectin various production vessels and equipment atthe gas/water/oil separation facility.5 (Similartank bottoms will accumulate in separationequipment at offshore facilities.) These tankbottoms (also sometimes referred to as basicsediments and water [BS&W]) are primarily inertrock or sand particles but may contain tracemetallic and hydrocarbon contaminants. Often,tank bottoms that settle from oil will exhibitcharacteristics of hazardous wastes, primarilybecause of the presence of benzene. Tankbottoms can safely accumulate in processequipment until that point where their presenceaffects the proper functioning of that equipment.At that point, the equipment must be cleaned

and this �material in process� must be removed,characterized for its hazardous or nonhazardousproperties, and managed accordingly. Any tankbottoms produced at the North Slope that exhibithazardous waste characteristics would betransported out-of-state to permitted TSDFs.Tank bottoms that are nonhazardous can bedisposed of at the Oxbow Landfill.6

Maintenance Wastes. Infrastructuremaintenance involves the use of various paintsand coatings for corrosion control of equipmentand structures and solvents and cleaning agentsfor equipment cleaning or surface preparationprior to the application of corrosion controlcoatings. While some of these maintenance-related wastes may be hazardous, collectively,infrastructure maintenance activities generateonly relatively small amounts of wastes.Maintenance-related wastes that are RCRAwastes would be transported to out-of-stateRCRA-permitted TSDFs. Nonhazardousmaintenance wastes would be disposed of in theOxbow Landfill.

Throughout their working lives, productionwells require routine maintenance, rejuvenation,or rebuilding. Wastes from these activities,together with wastes from initial well installationand development are collectively known as�Associated Wastes.� Water contained informations normally exists at elevatedtemperatures and pressures, thereby enhancingthe solubility of inorganic and polar organicspecies also present in the formation. As thiswater is brought to the surface along with oil andgas, its pressure and temperature begin toequilibrate to ambient conditions. Chemicalsdissolved in the water then begin to precipitate,forming scale on downhole7 equipment andaboveground wellheads and other productionequipment that comes in contact with this water.

APPENDIX C C-42

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8 NORM wastes are excluded from regulation as RCRA wastes by basic statutory construction. The State of Alaskahas not developed rules that apply to the management and disposal of NORM wastes. Regulations promulgatedby the U.S. Nuclear Regulatory Commission potentially apply to disposal of NORM wastes. However, NORMwastes have activity levels ranging from 526 to 12,000 pCi/g and average 7,690 pCi/g, levels that are belowregulatory concern.

If allowed to build up, this scale will ultimatelyinterfere with production rates. One of theprimary purposes of periodic rejuvenation ofproduction wells is the removal of accumulatedscale. Because the scale primarily consists ofsodium and calcium chlorides and carbonates,with trace amounts of barium salts, strongmineral acids such as hydrochloric andhydrofluoric are often used to �descale� the well.Well maintenance may also involve replacingsegments of well casings or downholeequipment and the introduction of corrosioninhibitors, typically containing zinc carbonateand aluminum bisulfate. Additional acids may beintroduced into the well after maintenance orrebuilding to stimulate future oil production. Inmost instances, the acidic descaling solutionsare reinjected into the well or delivered to theNorth Slope Class II injection well for disposal.

NORM Wastes. As stated previously,scale formation is a continuing occurrence ateach production well. Scale can also form onequipment at the Gathering Facility. When theoil-bearing formation contains naturally occurringradioactive species, such as radioactiveisotopes of uranium or thorium and theirrespective radioactive decay products (ordaughters), the scale that forms will exhibitradioactive properties and may require specialmanagement for the purposes of both controllingworker exposures to radioactivity and providingfor proper ultimate disposal. The extent to whichNORM wastes will form and the levels ofradioactivity they display are functions primarilyof the natural occurrence and mobility of theradioactive species in the oil-bearing formation,and the amount of water produced in conjunctionwith the hydrocarbons. The radioactive speciesof greatest concern (from a worker exposureperspective) are radium-226 and radium-228,the salts of which exhibit generally highsolubilities in production waters. Otherradionuclides of concern, especially in naturalgas processing, are lead-210 and radon-222,

which is often present in natural gas (Smith1992).

The incidence of naturally occurring uraniumand thorium in the oil-bearing formations on theNorth Slope is relatively low; consequently, whileNORM species will be present in productionwaters and NORM scale will form on wellequipment, the resulting activity levels arerelatively low. No federal or state regulationscurrently exist that speak directly to themanagement of NORM wastes in Alaska.8

Nevertheless, North Slope drillers haveestablished formal procedures for managingpotentially NORM-contaminated by-productstreams and solid wastes (BP Amoco Alaska2001). These procedures call for routine surveysof work environments at the wellheads and thegas processing plant to determine workerexposure levels, establishing handlingprocedures for NORM-contaminated equipment,and the provision of general worker trainingregarding potential NORM hazards and properavoidance techniques. In past years,NORM-contaminated wastes were cleaned atBP Amoco�s centrally located Mukluk ColdStorage Yard by a special services contractorand cleaning solutions containing NORMspecies were disposed of in the Class II injectionwell (Johnson 1991). Under current procedures,all scale-encrusted equipment retrieved from allNorth Slope wells is stored at the Mukluk ColdStorage Yard until being removed for cleaningand disposal (Kany 2001). The area is posted,equipment is wrapped in plastic or otherwiseplugged to prevent the airborne release of thescale, and the ground surface is routinelysurveyed by BP Amoco health physicists forevidence of release of radioactive species.Surveys conducted in June 2000 clearly indicatethat migration of radioactive contamination is notoccurring (BP Amoco Alaska 2000; McArthur2000). Periodically, NORM-contaminatedequipment is transported by contractor to acommercial firm in Louisiana for cleaning.NORM-contaminated scale is disposed of in aClass II injection well in east Texas, and the

C-43 APPENDIX C

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9 Domestic wastewaters are waters from sinks, showers, and laundry and food preparation areas. Sanitarywastewaters are generated from toilets and routinely contain fecal coliform bacteria.

cleaning company takes possession of thecleaned equipment for salvage value as partialcompensation for its services. The cleaningcontractor routinely provides BP Amoco Alaskawith completed waste transportation manifestsas well as quality control analytical results(Taylor 2001b; ARS 2001).

North Slope Support Facilities.Various suppliers of oil field equipment maintainstorage areas in Deadhorse. Likewise,numerous special service contractors (e.g., wellinstallation contractors) maintain offices andbusiness units in Deadhorse. Wastes associatedwith maintaining living quarters for theseindividuals include domestic solid wastes (fromresidences and food service facilities) anddomestic and sanitary wastewaters.9 Solidwastes are disposed of at the Oxbow Landfill.Domestic and sanitary wastewaters arecombined with similar wastes generated fromliving quarters and business locationsmaintained by the drilling companies.Management of those wastewaters is discussedbelow.

North Slope support facilities also includeaboveground transfer pipeline maintained by thevarious North Slope drilling companies thatinterconnect onshore wellheads, the CentralGathering Facility, and TAPS PS 1 andsubmarine transfer pipelines that interconnectthe offshore wellheads with PS 1. Collectively,these transfer pipelines constitute approximately1,123 mi in length (USACE 1999). Althoughthese pipelines are smaller in scale and lesssophisticated in their overall designs than theTAPS, their maintenance requirements areassumed to be similar to those for the TAPS.Because the pipelines traverse relatively smalldistances over virtually level grades, pumpingsystems do not need to be as technicallycomplex at those at TAPS pump stations andtheir maintenance is much less involved.Procedures for maintaining corrosion control,preventing unacceptable degrees of curvature ordeformation, maintaining pipeline VSMs, andmaintaining overall asset integrity result inmaintenance-related wastes. Similarly to the

TAPS, most maintenance-related wastes for theNorth Slope transfer pipelines are expected tobe non-hazardous and are likely to be eligible fordisposal in the Oxbow Landfill. However,residues recovered from internal cleaning ofthese pipelines may exhibit hazardous wastecharacteristics. In addition to solid and/orhazardous wastes, maintenance of thesetransfer pipelines are likely to result in thegeneration of wastewaters from hydrostatictesting that routinely occurs. As with the TAPS, itis assumed that hydrostatic test water is eligiblefor discharge to the ground surface at the pointwhere it is generated under the authority andcontrol of an NPDES permit. Alternatively,hydrostatic test water may be eligible fordisposal in the North Slope Class II injectionwell. Response to spills or leaks from thesepipelines would result in remediation waste,some of which may display hazardouscharacteristics, however. All such hazardouswaste resulting from spill response must be sentto out-of-state RCRA TSDFs.

North Slope Workforce. Theexigencies of weather on the North Slopetogether with the remoteness of the area requirethat the North Slope oil field workers reside at ornear their work sites. Consequently, all NorthSlope oil field workers reside in dormitories atDeadhorse or at offshore oil platforms.Maintenance of these housing facilities results inthe generation of domestic solid wastes(including food preparation wastes) anddomestic and sanitary wastewaters. Solidwastes are disposed of in the Oxbow Landfill atDeadhorse. A small incinerator is alsooperational at the Oxbow Landfill in whichcombustible, nonhazardous solid wastes can beburned before being placed in the landfill.Domestic and sanitary wastewaters arecombined with similar wastes generated fromNorth Slope special service contractor facilitiesfor treatment and disposal. A number ofmanagement options are available. Thewastewaters undergo biological treatment, andtreated effluents are discharged under NPDESpermits to either area lakes or to the BeaufortSea. When those discharge options are not

APPENDIX C C-44

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10 Some chemicals commonly categorized within the refining industry as feedstock chemicals can also be used asfuels (e.g. ethane, propane, butane) and solvents (e.g. benzene, toluene, xylene).

available (because of weather, access, or frozenreceiving water bodies), treated wastewaters canalso be injected into the Class II injection well onthe North Slope that routinely receivesproduction waters (Kitagawa 2002).

Individual NPDES permits also cover thedischarge of seawater treatment plant residues(natural salts and solids removed from seawateras it is processed for industrial and potable use)and fire-control system test water (intermittentfresh or saltwater discharges from fire-controlequipment (BPXA 2001). The EPA and ADEChave developed a general NPDES permit for oiland gas facilities on the North Slope. The NorthSlope General Permit covers the temporary orintermittent discharges of sanitary wastewater(up to 15,000 gal/d); domestic wastewater;gravel pit dewatering (up to 1.5 million gal/d) totundra, water bodies, or for use in road wateringand ice road/ice pad construction; constructiondewatering; and hydrostatic test water (from newpipelines only, not from pipelines that havecarried oil) (BPXA 2001). NPDES storm-waterpermits allow discharges of uncontaminatedrainwater and snowmelt. Arctic drilling andproduction pads do not have conventional stormdrains, so storm-water discharges are in theform of surface runoff during the brief springthaw season (BPXA 2001).

C.7.3 Wastes Associated withOil Refining Operations

Currently, four petroleum refineries areoperating in Alaska: the Petro-Star Refinery onthe Kenai peninsula, the Petro-Star ValdezRefinery, Petro-Star North Pole Refinery, andWilliams Alaska Petroleum Co. North PoleRefinery (formerly, the MAPCO Refinery). Ofthese, only the last three receive crude oil fromthe TAPS. Consequently, only activities at thethree refineries in North Pole and Valdez areconsidered to be within the area of interest andto result in cumulative impacts for the purpose ofthis EIS. Petroleum refining is the physical,thermal, and chemical separation of crude oilinto its major distillation fractions, which are thenprocessed through a series of separation andconversion steps into finished petroleum

products. Unless otherwise noted, the genericdescriptions and data for petroleum refining thatare presented below were obtained from theEPA Office of Compliance Sector NotebookProject �Profile of the Petroleum RefiningIndustry� (EPA 1995). Oil refining is in SIC 2911.

Refinery Products. The primaryproducts of petroleum refineries fall into threemajor categories: fuels (e.g., motor gasoline,diesel and distillate fuel oil, liquefied petroleumgas, jet fuel, residual fuel oil, kerosene, andcoke); finished nonfuel products (e.g. solvents,lubricating oils, greases, petroleum wax,petroleum jelly, and asphalt); and chemicalindustry feedstocks (e.g., naphtha, ethane,propane, butane, ethylene, propylene, butylenes,butadiene, benzene, toluene, and xylene).10

Petroleum refineries are complex and consist ofmultiple physical and chemical operationsdepending upon the properties of the crude oilbeing refined and the desired products. Forthese reasons, no two refineries are alike.Portions of the outputs from some processes arefed back into the same process, fed to newprocesses, fed back to a previous process, orblended with other outputs to form finishedproducts. Refining crude oil into usefulpetroleum products can be separated into twophases and a number of supporting operations.The first phase is desalting of crude oil and thesubsequent distillation into its variouscomponents or �fractions.� The second phase ismade up of three different types of �downstream�processes: combining, breaking, and reshaping.Downstream processes convert some of thedistillation fractions into petroleum productsthrough any combination of different cracking,coking, reforming, and alkylation processes.Supporting operations may include wastewatertreatment, sulfur recovery, additive production,heat exchanger cleaning, blowdown systems,blending of products, and storage of products.

Refinery Wastes. The nature andvolumes of wastes generated at refineries arefunctions of the quality and throughput of the rawmaterials (crude oil) as well as the productsbeing generated. Recent crude oil throughputs

C-45 APPENDIX C

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11 See footnote 9.

12 Industrial areas are defined in 40 CFR 122.26(b)(14)(ii) and include facilities in SIC 29.

for the refineries within the area of interest areprovided in Section 4.7.4.2. Because operationsat refineries change frequently in response tomarket demands, a review of the historical wastegeneration data for one of the Alaska refineriesis considered to be sufficiently descriptive ofwastes that may be generated at any of theAlaska refineries in future years. The followingdiscussions, therefore, incorporate informationand data specific to the Williams North PoleRefinery, but are intended to be generallyrepresentative of wastes from any of the othertwo refineries within the area of interest forthis EIS.

Wastewater. The petroleum refiningindustry uses relatively large volumes of water.Four types of wastewater are produced: surfacewater runoff (precipitation draining fromindustrialized land areas), cooling water,process water, and domestic/sanitarywastewaters.11 Surface water runoff isintermittent and will contain constituents fromspills to the surface, leaks in equipment, and anymaterials that may have collected in drains.Storm-water runoff from oil refineries would becontrolled by the facility�s NPDES permit forstorm water associated with industrial activityand would normally be routed to the nearestsurface water body. Federal regulationsgoverning the discharge of storm water fromindustrial areas12 requires the capture andtreatment of storm water at all petroleumrefineries, including removal of large fraction ofboth conventional pollutants, such as suspendedsolids and constituents that contribute to thewater�s biological oxygen demand (BOD), aswell as toxic pollutants, such as certain metalsand organic compounds.

A large portion of water used in petroleumrefining is used for cooling. Cooling watertypically does not come into direct contact withprocess oil streams and therefore has lesspotential for hydrocarbon contamination than doprocess wastewaters. Most cooling water isrecycled with only a small bleed or blowdownstream diverted to the wastewater treatment unit

at each cooling water cycle to control theconcentration of contaminants and the solidscontent. The water used for cooling oftencontains chemical additives such as chromates,phosphates, and antifouling biocides to preventscaling of pipes and biological growth. It mayalso contain some level of oil contaminationcaused by leaks in the process equipment.Process wastewater arises from desalting ofcrude oil, steam stripping operations, drainagefrom product fractionation operations, and boilerblowdown. Because process water comes intocontact with the oil process streams, it is usuallyhighly contaminated with the polar hydrocarbonsroutinely present in oil. Oily water generatedduring routine heat exchanger cleaning is alsoconsidered process water.

Petroleum refineries typically utilize primaryand secondary wastewater treatment. Primarywastewater treatment consists of separation ofoil, water, and solids in two stages. The firststage is an oil/water separator where the oil isallowed to float to the surface and be skimmedoff, and solids settle to the bottom to be scrapedoff into a sludge hopper. The second stage maybe a series of settling ponds or DAF, where air isbubbled through the wastewater and both oil andsuspended solids are skimmed off the top.Chemicals, such as ferric hydroxide or aluminumhydroxide, can be used to coagulate impuritiesinto a froth or sludge that can be skimmed off thetop. After primary treatment, wastewater can bedischarged to a POTW or undergo secondarytreatment before being discharged directly tosurface waters under an appropriate NPDESpermit. Some refineries use an additional stageof wastewater treatment, called polishing, tomeet NPDES permit pollutant discharge limits.Polishing usually includes filtering (e.g., carbon,anthracite, or sand).

Williams North Pole Refinery holds anNPDES permit issued by EPA Region 10, for thedischarge of wastewater into a former gravel pitlocated on the Williams property. In addition,process wastewater is discharged to the City ofNorth Pole Municipal Sewage Treatment Plant(EPA 2002).

APPENDIX C C-46

Hazardous and Solid Wastes.Primary wastewater treatment generates wastesthat may be considered hazardous, includingoil/water separator sludge, primary treatmentsludge, sludges from other gravitationalseparation techniques, float from DAF units, andwastes from settling ponds. Secondarywastewater treatment also generates wastes,including biomass waste that is typically treatedthrough digestion by anaerobic bacteria and thendewatered. This oily wastewater treatment wastemay contain contaminants (e.g., chromium orlead) that would require it to be managed as aRCRA hazardous waste. The periodic cleaningof heat exchangers may produce hazardouswaste sludges because of the use of chromiumas an additive to cooling water.

Other refinery wastes include various typesof sludge (e.g., oily waste sludge, tank bottoms,calcium chloride sludge from isomerizationprocesses and neutralized sulfuric acid, orcalcium fluoride sludge from alkylationprocesses), spent process catalysts, and spentclay filtering media. Treatment of these wastesincludes incineration, land treating off-site, landfilling on-site, land filling off-site, chemicalfixation, neutralization, and other treatmentmethods. A number of wastes commonlygenerated at refineries are EPA listed hazardouswastes, including oil separator sludge (EPAHazardous Waste No. K051); slop oil emulsionsolids (EPA Hazardous Waste No. K049);dissolved air flotation floats (EPA HazardousWaste No. K048), and heat exchanger bundlesludge (EPA Hazardous Waste No. K050). Inaddition, some wastes may contain hazardousconstituents (e.g., lead, chromium, or benzene)and must be managed as hazardous waste.Because there are no EPA-permitted hazardouswaste treatment or disposal facilities located inAlaska, oil refinery wastes that are characterizedor listed as hazardous wastes would have to beshipped off-site and out of state for treatmentand final disposal.

Williams North Pole Refinery is a largequantity generator of RCRA hazardous wastes.In 1997, Williams North Pole Refinery generated43 tons of hazardous waste (EPA 2002), whichwas all shipped off-site to out-of-state TSDFs.These hazardous wastes included benzene-contaminated wastes; heat exchanger bundle

cleaning sludge; ignitable, reactive sludge; usedsolvents contaminated with lead and benzene;laboratory wastes; used filter media; tankremoval sludge; used batteries; paint wastes;and contaminated air stripping media. Somewastes from Williams North Pole Refinery areshipped off-site for energy recovery.

Those solid wastes characterized asnonhazardous wastes (e.g., packing materials ornonhazardous sludge) can be disposed of inon-site landfills; in off-site, local solid wastelandfills; or shipped out-of-state to appropriatelypermitted landfills. Some outputs, such as sulfur,acetic acid, phosphoric acid, and recoveredmetals, are sold as by-products and transportedoff-site.

C.7.4 Waste Impacts fromTanker Operations at theValdez Marine Terminal

Wastes associated with oil tanker visits tothe Valdez Marine Terminal include tankerballast and bilge water and domestic solidwastes generated on board (including somepotential medical wastes) during the ship�svoyage to the Valdez Marine Terminal.

Oil tankers berthing at the Valdez MarineTerminal discharge their ballast and bilge watersto the BWTF at the Valdez Marine Terminal fortreatment before discharge to Prince WilliamSound (e.g., removal of oil). Average inflows oftanker ballast and bilge water are 400,000 bbl/d.A number of factors influence this total,including, primarily, the frequency of tanker visits(in general, a function of crude oil pipelinethroughput as well as the capacities of eachtanker) and the design of the tankers. The OilPollution Act of 1990 requires that, afterJanuary 1, 2015, all vessels operating in theUnited States navigable waters or the ExclusiveEconomic Zone of the U.S. be equipped with adouble hull, or double containment system. Thestatute also establishes a schedule by whichconversions of existing vessels must occur, onthe basis of the vessel�s year of commissioning,gross tonnage, and salvage value. It isanticipated that some double-hulled tankers willalso have segregated ballast tanks (i.e., ballasttanks that are separate from crude oil tanks). For

C-47 APPENDIX C

these vessels, the volume of ballast waterrequiring treatment at the BWTF would bedramatically reduced since the potential for oilcontamination of the seawater ballast does notexist. However, it is also possible that othervessels without segregated ballast tanks that stillcomply with the double-hull requirement mayalso still be part of the Valdez Marine Terminalfleet and would require treatment of their ballastwater before discharge to Prince William Sound.Further, double-hulled tankers with segregatedballast tanks may still need to use cargo tanksfor additional ballast storage to ensure stabilityin certain open sea conditions. Thus, conversionof the Valdez Marine Terminal tanker fleet tocomply with double-hull requirements woulddramatically reduce, but would not completelyeliminate, the volume of ballast water treated inthe BWTF. It can be reliably assumed that themaximum reduction in ballast water volumeswould be realized by January 2015. However, aschedule for reductions in the interim period isdifficult to predict since many vessel owners arereconfiguring their fleet, or purchasing newvessels on more aggressive schedules thanthose required by the statute. Regardless of theirhull design, tankers visiting the Valdez MarineTerminal would still have bilge water that wouldrequire treatment before discharge.

Domestic solid wastes generated on boardare managed as �International Wastes� andtreated as potentially biohazardous. As a serviceto the berthing tankers, upon request, the ValdezMarine Terminal accepts domestic solid wastes,separately bags those wastes, and delivers themto a commercial firm for sterilization and ultimatedisposal in a municipal landfill. The quantities ofdomestic waste are very limited. Valdez MarineTerminal personnel report that requests fromvessel captains for assistance with disposal ofdomestic solid wastes are rare (Edwards 2002b).

Personnel at Valdez Marine Terminal reportthat it does not treat domestic and sanitarywastewaters generated by the tankers. Thesewastewaters are treated according to existingU.S. Coast Guard and ADEC regulations anddischarged to the ocean. None of the tankerscommingle domestic or sanitary wastewaterswith ballast waters (Edwards 2002b). Finally,wastes generated during the vessel�s trip toPrince William Sound as a result of maintenance

or repair of on-board mechanical systems arenot off-loaded at Valdez but rather return with thevessel to its home port for treatment or disposal(Edwards 2002b).

C.7.5 Wastes Associated withNatural Gas Pipelines

The proposed construction and operation ofthe natural gas pipeline would have the potentialto generate wastes. Waste impacts would beboth short term, associated with initialconstruction, and long term, associated withsubsequent operation. During construction,substantial amounts of domestic solid waste anddomestic and sanitary wastewaters would begenerated in support of the constructionworkforce. In addition to the pipeline, the naturalgas system would involve construction of anatural gas separation and treatment facility onthe North Slope and compressor stations alongthe pipeline route. If natural gas was brought toValdez, a gas liquefaction facility and marineterminal might be located at Anderson Bay inPrince William Sound. Because the temperatureof the gas could be controlled before the gaswould be introduced into the pipeline, the entirelength of the pipeline could be buried,notwithstanding localized factors that wouldpreclude burial.

Wastes associated with operation of anatural gas system would include wastesresulting from the support of a workforce andwastes associated with maintenance of thepipeline. Although less complex in its designthan the TAPS, the natural gas pipeline wouldstill require maintenance, and such activitieswould also generate wastes, many of whichwould be similar to those resulting frommaintenance of the natural gas TAPS. Becausethe natural gas project is only at a preliminaryconceptual stage, no additional details can beprovided about the amounts or types ofoperation wastes that would result or about theirultimate disposal.

The liquefied natural gas (LNG) plant wouldgenerate industrial wastewaters related to plantoperations as well as domestic and sanitarywastewater in support of the workforce. Inaddition, LNG tankers visiting the LNG plant

APPENDIX C C-48

could generate bilge/ballast wastewaters thatwould have to be treated and discharged intoPrince William Sound under the auspices ofappropriate NPDES permits. Prince WilliamSound would then receive treated wastewatersfrom both the Valdez Marine Terminal and anynew LNG plant.

In addition, the LNG plant would generatesolid wastes that could be disposed of in the Cityof Valdez municipal landfill. They would be inaddition to any solid wastes generated at theValdez Marine Terminal and disposed of at themunicipal landfill. Under the no-actionalternative, solid wastes from the LNG plantcould continue to be disposed of at the municipallandfill, even though Valdez Marine Terminaloperations ceased. However, under the no-action alternative, solid wastes generated duringpipeline and Valdez Marine Terminal closureand dismantlement could also be disposed of atthe municipal landfill.

Finally, the construction and operation of theLNG plant might cause an increase in thepopulation of Valdez and other nearbycommunities, together with increases indomestic solid wastes and domestic andsanitary wastewaters, the management of whichrepresents cumulative impacts in addition tothose already resulting from other activities,including those associated with the ValdezMarine Terminal operational workforces. Underthe no-action alternative, these cumulativeimpacts would be less as employment related tothe Valdez Marine Terminal declined.

C.8 References forAppendix C

ADEC (Alaska Department of EnvironmentalConservation), 1996, Air Quality Control PermitNo. 9572-AA012.

Alaska Oil and Gas Association, 2001,�Underground Injection of Wastes,� in TechnicalBriefs: Alaska�s North Slope Oilfields,Anchorage, Alaska.

APSC (Alyeska Pipeline Service Company),undated, Pollution Prevention Program Guide.

APSC, 1997, Final NPDES Permit No. AK-002324-8, Authorization to Discharge under theNational Pollutant Discharge EliminationSystem, Anchorage, Alaska.

APSC, 1999a, Alyeska Linewide PetroleumContamination Soil Stockpile Management Plan,Anchorage, Alaska, Oct.

APSC, 1999b, Storm Water Pollution PreventionPlan for OMS 5-2, Fairbanks, Alaska, March 29.

APSC, 2000a, Environmental ManagementSystem Compliance Manual, Rev. 01,Anchorage, Alaska.

APSC, 2000b, �Hazardous MaterialsManagement,� Section 8 in EnvironmentalProtection Manual, EN-43-1, Anchorage, Alaska.

APSC, 2000c, �Waste Management,� Section 5in Environmental Protection Manual, EN-43-2,Anchorage, Alaska.

APSC, 2000d, APSC Payment Requests forBPXA Payment to City of Valdez for 1999 UtilityWaste Baler Services, Anchorage, Alaska.

APSC, 2000e, Estimate of Wastewater Flowthrough Outfalls 1 and 2 at Valdez MarineTerminal, Valdez, Alaska.

APSC, 2000f, Sanitary Sewer Manual/AlyeskaMarine Terminal (SS-45), Rev. 4, Fairbanks,Alaska, Oct. 16.

APSC, 2000g, APSC Payment Requests forPayment to City of Valdez for 1999 Utility WasteWater Offload Services, Valdez, Alaska.

APSC, 2001a, Alyeska Pollution PreventionAccomplishments, Appendix A (Draft), 2nd Ed.,Rev. 0, Anchorage, Alaska, March 2.

APSC, 2001b, Best Management Practices Planfor Ballast Water Treatment, Alyeska MarineTerminal, MP-69-1, 2nd Ed., Rev. 03,Anchorage, Alaska.

APSC, 2001c, Audit Compliance TrackingSystem Closure Package, Ref. CAP00609, Re:Test-NORM Conducted on Sludge from Tank111 at S01 in 199, Anchorage, Alaska.

C-49 APPENDIX C

APSC, 2001d, Valdez Marine Terminal Contaminated Soil Stockpile, one page of datasupplied by M. Brown, Alyeska Pipeline ServiceCompany, Anchorage, Alaska.

ARS (American Radiation Services, Inc.), 2001,Analytical Sampling Results for Mukluk NORMSamples, Baton Rouge, La., Aug. 16.

Authier, B., 2002, personal communication fromAuthier (Alyeska Pipeline Service Company,Anchorage, Alaska) to R. Kolpa (ArgonneNational Laboratory), April 15.

BP Amoco Alaska, 2000, Survey of NORM-Contaminated Tubulars, Equipment, and YardSurface at Mukluk Cold Storage Pad Deadhorse,Completed on June 21 and 22, 2000, July 5.

BP Amoco Alaska, 2001, Naturally OccurringRadioactive Material (NORM) Procedure,UPS-US-SK-GPB-WOA-HSE-DOC-00020-4,Rev. March 23, Anchorage, Alaska.

BPXA (BP Exploration [Alaska] Inc.), 2001, BPand the Environment on Alaska�s North Slope,Sept.

BPXA (BP Exploration [Alaska} Inc.), 2001, BPand the Environment on Alaska�s North Slope,Sept.

Burlington Environmental, Inc., 2001, UniformHazardous Waste Manifest 18330, Seattle,Wash., Aug. 27.

Chapple, T., 1995, Re-Use of Asphalt andSandblast Media, letter from Chapple (StatePipeline Coordinator�s Office, Anchorage,Alaska) to J. Dayton (Alyeska Pipeline ServiceCompany, Anchorage, Alaska), April 26.

City of Valdez, 2001, City of Valdez, Non-Residential Wastewater Discharge Permit(Permit No. A092001-3), Effective DateNovember 1, 2001, Valdez, Alaska.

Clearwater/Golder J.V., 2000, ThermalRemediation of Stockpile Soils, PS 01, 02, 03,04, ev10, 12, final report, prepared byClearwater/Golder J.V., Anchorage, Alaska, forAlyeska Pipeline Service Company, Feb. 16.

Edwards, L., 2002a, personal communicationfrom Edwards (Alyeska Pipeline ServiceCompany, Valdez, Alaska) to R. Kolpa (ArgonneNational Laboratory), April 17.

Edwards, M., 2002b, personal communicationfrom Edwards (Alyeska Pipeline ServiceCompany, Valdez, Alaska) to R. Kolpa (ArgonneNational Laboratory), March 21.

EMCON Alaska, Inc., 1995, PCB InventoryUpdate, Anchorage, Alaska.

EPA (U.S. Environmental Protection Agency),1986, Test Methods for Evaluating Solid Waste:Physical/Chemical Methods, EPA-530-SW-846,3rd Ed., Nov. 1986 and subsequent updates,Office of Solid Waste, Washington, D.C., Sept.

EPA, 1993, Authorization to Discharge under theNational Pollutant Discharge EliminationSystem, Permit No. Alaska-005056-3, issued toAlyeska Pipeline Service Company, Anchorage,Alaska, by EPA Region 10, Seattle, Wash.,June 30.

EPA, 1995, Office of Compliance SectorNotebook Project, Profile of the PetroleumRefining Industry, EPA/310-R-95-013, Office ofEnforcement and Compliance Assurance, Sept.Available at http://es.epa.gov/oeca/sector/sectornote/pdf/petrefsn.pdf.

EPA, 2000, Office of Compliance SectorNotebook Project, Profile of the Oil and GasExtraction Industry, EPA/310-R-99-006, Office ofEnforcement and Compliance Assurance, Oct.Available at http://es.epa.gov/oeca/sector/sectornote/pdf/oilgas.pdf.

EPA, 2002, Envirofacts Warehouse. Available athttp://oaspub.epa.gov/enviro. AccessedMarch 18, 2002.

Ferrell, L., 2001, EPCRA Section 312 Tier II2000 Annual Submittal, APSC Facilities,Anchorage, Alaska.

Glenbrook Nickel Company, undated, GreenDiamond Abrasives, product specification,Riddle, Oregon.

APPENDIX C C-50

Gryder-Boutet, D.E., 1996, Documentation ofVerbal Approval Trans Alaska Pipeline SystemWastewater Disposal Permit Application,Anchorage, Alaska.

Johnson, D., 1991, Disposal of NaturallyOccurring Radioactive Material (NORM), letterfrom Johnson (Alaska Oil and Gas ConservationCommission, Anchorage, Alaska) toM. Frampton (Prudhoe Bay/Lisburne FacilityOperations, Arco Alaska, Anchorage, Alaska),Oct. 10.

Kany, G., 2001, personal communication fromKany (BP Amoco Alaska, Anchorage, Alaska) toR. Kolpa (Argonne National Laboratory), Oct. 1.

Kitagawa, J., 2002, personal communicationfrom Kitagawa (BP Amoco Alaska, Deadhorse,Alaska) to R. Kolpa (Argonne NationalLaboratory), March 20.

Lipchak, R. 1995, Management and Re-use ofSandblast Sand and Asphalt, Anchorage,Alaska.

McArthur, A., 2000, BP Amoco Mukluk ColdStorage Yard Survey of NORM-ContaminatedEquipment, readings taken June 21 and 22,Central Environmental, Inc., Houston, Texas.

Mikkelsen, D., 1997, memorandum fromMikkelsen to J. Riordan (Alyeska PipelineService Company, Anchorage, Alaska), as citedin TAPS Owners (2001).

Morton, J.A., 1995, Request for Exclusion fromthe Definition of �Solid Waste�: Asphalt andNon-Hazardous Sandblast Media to Be Reused,letter from Morton (Alyeska Pipeline ServiceCompany, Anchorage, Alaska) to J. Chatham(Alaska Department of EnvironmentalConservation, State Pipeline Corridor RegionalOffice, Anchorage, Alaska), April 13.

Noll, J., 2001, Wastewater Discharge PermitNo. 99-VSC-030, Fairbanks, Alaska.

Norton, J.D., 2001a, e-mail with APSC FireSafety and Industrial Hygiene data on asbestosfrom Norton (Alyeska Pipeline ServiceCompany, Anchorage, Alaska) to R. Kolpa(Argonne National Laboratory).

Norton, J.D., 2001b, e-mail on NORM surveys atValdez Marine Terminal provided by R. Palmer,Physics Technician, Valdez Marine Terminal,from Norton (Alyeska Pipeline ServiceCompany, Anchorage, Alaska) to R. Kolpa(Argonne National Laboratory), Sept. 20.

OIT Inc., 1999, Certification of ThermalTreatment (2,302 tons of POL-contaminated soilfrom PS 1, 2, 3, and 4 for ClearwaterEnvironmental, Anchorage, Alaska), North Pole,Alaska, Oct. 29.

OIT Inc., 2001a, Certification of ThermalTreatment (120.52 tons of POL-contaminatedsoil from PS 9, for IT Alaska, Fairbanks, Alaska),North Pole, Alaska, June 5.

OIT Inc., 2001b, Certification of ThermalTreatment (28 drums of POL-contaminated soilfrom PS 9, for IT Alaska, Fairbanks, Alaska),North Pole, Alaska, June 4.

Owen, A., 2000, Golden Heart Utilities (GHU)Special Wastewater Discharge Permit 00S-04,Fairbanks, Alaska.

Redmond, R., 1994, Fuel Gas Line Coating:A729 Anomaly Investigation-Blast Materials,e-mail from Redmond (Project Engineer,Alyeska Pipeline Service Company) toT.J. Arminski (Alyeska Pipeline ServiceCompany).

Scheidt, D., 2000, City of Valdez, IndustrialWastewater Discharge Permit (Permit No.99-01), Effective Date June 1, 1999, Valdez,Alaska.

Schmidt, E., 2000, Thermal Remediation ofContaminated Gravel, Pump Stations 1 and 2,Letter No. AIC00-NS-209, from Schmidt (AlaskaInterstate Construction, L.L.C., Anchorage,Alaska) to A. Church (IT Alaska, Inc., Fairbanks,Alaska), Aug. 30.

Schanbl, W., 1996, Subcontract No. 96-620-0013, APC Job No. 620, Letter No. AIC96-NS-209, from Schnabl (Alaska InterstateConstruction, L.L.C., Anchorage, Alaska), to S.Sessum (Alaska Petroleum Contractors, Inc.,Anchorage, Alaska), Sept. 16.

C-51 APPENDIX C

Seward, B., 1999, 1999 Biennial Reports,Alyeska Pipeline Service Company, Fairbanks,Alaska.

Seward, B., 2000a, Alyeska Solid WasteDisposal Sites Quarterly Report 1st Quarter2000, Letter No. 00-15661 with attachment fromSeward (Alyeska Pipeline Service Company,Fairbanks, Alaska) to L. Ogar (AlaskaDepartment of Environmental Conservation,Anchorage, Alaska), April 13.

Seward, B., 2000b, Alyeska Solid WasteDisposal Sites Quarterly Report 2nd Quarter2000, Letter No. 00-16040 with attachment fromSeward (Alyeska Pipeline Service Company,Fairbanks, Alaska) to L. Ogar (AlaskaDepartment of Environmental Conservation,Anchorage, Alaska), Oct. 25.

Seward, B., 2000c, Alyeska Solid WasteDisposal Sites Quarterly Report 3rd Quarter2000, Letter No. 00-16419 with attachment fromSeward (Alyeska Pipeline Service Company,Fairbanks, Alaska) to L. Ogar (AlaskaDepartment of Environmental Conservation,Anchorage, Alaska), Oct. 25.

Seward, B., 2000d, 1999 Recycling Numbers,e-mail from Seward (Alyeska Pipeline ServiceCompany, Fairbanks, Alaska) to R. Kolpa(Argonne National Laboratory), April 10.

Seward, B., 2001a, Corrected Notification ofRegulated Waste Activity, EPA Form 8700-12,Alyeska Pipeline Service Company, Fairbanks,Alaska.

Seward, B., 2001b, Incinerated Solid andMedical Waste, e-mail from Seward (AlyeskaPipeline Service Company, Fairbanks, Alaska)to R. Kolpa (Argonne National Laboratory),Dec. 19.

Seward, B., 2001c, New Solid Waste DisposalSite Permit for 117-1B, Alyeska Pipeline ServiceCompany, Fairbanks, Alaska.

Seward, B., 2001d, Memorandum: New SolidWaste Disposal Site Permits for 100-1 and 38-1,Alyeska Pipeline Service Company, Fairbanks,Alaska.

Seward, B., 2001e, Alyeska Solid WasteDisposal Sites Quarterly Report 1st Quarter2001, Letter No. 01-16992 with attachment fromSeward (Alyeska Pipeline Service Company,Fairbanks, Alaska) to Monroe (AlaskaDepartment of Environmental Conservation,Fairbanks, Alaska), April 12.

Seward, B., 2001f, Alyeska Solid WasteDisposal Sites Quarterly Report 2nd Quarter2001, Letter No. 01-17337 with attachment fromSeward (Alyeska Pipeline Service Company,Fairbanks, Alaska) to Monroe (AlaskaDepartment of Environmental Conservation,Fairbanks, Alaska), July 10.

Seward, B., 2001g, Alyeska Solid WasteDisposal Sites Quarterly Report 4th Quarter2000, Letter No. 01-16704 with attachment fromSeward (Alyeska Pipeline Service Company,Fairbanks, Alaska) to L. Ogar (AlaskaDepartment of Environmental Conservation,Anchorage, Alaska), Jan. 16.

Seward B., 2002a, record of telephoneconversation between Seward (Alyeska PipelineService Company, Fairbanks, Alaska) andR. Kolpa (Argonne National Laboratory), Jan. 3.

Seward, B., 2002b, record of telephoneconversation between Seward (Alyeska PipelineService Company, Fairbanks, Alaska) andR. Kolpa (Argonne National Laboratory), Jan. 7.

Smith, K., 1992, An Overview of NaturallyOccurring Radioactive Materials (NORM) in thePetroleum Industry, ANL/EAIS-7, ArgonneNational Laboratory, Argonne, Ill., Dec.

Sweeney, J., 2002, personal communicationfrom Sweeney (Alyeska Pipeline ServiceCompany, Anchorage, Alaska) to R. Kolpa(Argonne National Laboratory), April 15.

TAPS Owners (Trans Alaska Pipeline SystemOwners), 2001, Environmental Report for TransAlaska Pipeline System Right-of-Way Renewal(Draft), Anchorage, Alaska.

Taylor, M.S., 2001a, e-mail from Taylor (BPAmoco, North Slope, Alaska) to D. Cook(Alyeska Pipeline Service Company, Fairbanks,Alaska), Sept. 7.

APPENDIX C C-52

Taylor, M.S., 2001b, personal communicationfrom Taylor (BP Amoco Alaska, Deadhorse,Alaska) to R. Kolpa (Argonne NationalLaboratory), Oct. 2.

USACE (U.S. Army Corps of Engineers), 1999,Final Environmental Impact Assessment,Beaufort Sea Oil and Gas Development/Northstar Project, Alaska District, Anchorage,Alaska.

Willson, W., 2002, letter from Willson (AlyeskaPipeline Service Company, Valdez, Alaska) toAlaska Department of EnvironmentalConservation, April 17.

D-1

Appendix D:

Subsistence in the Vicinity of the TAPS

APPENDIX D D-2

D-3

Appendix D:Subsistence in the Vicinity of the TAPS

D.1 Introduction

Subsistence in Alaska refers to �thecustomary and traditional uses by rural Alaskaresidents of wild, renewable resources for directpersonal or family consumption� (FederalSubsistence Board 1999). Subsistence activitiescan involve hunting, fishing, collecting, ortrapping. Resources harvested include fish, landmammals, marine mammals and invertebrates,riverine invertebrates, and assorted plants(including wood). Uses of these resourcesinclude food, clothing, fuel, transportation,construction, art, crafts, exchange, home goods(e.g., sleeping mats), and customary trade(Wolfe 2002). Rural communities, in partbecause they have limited alternative means ofobtaining key resources and in part because oftheir heritage of living off the land, often relyheavily on subsistence.

Subsistence in rural Alaska tends to playboth economic and sociocultural (includingreligious and ceremonial) roles. Although all ofthe uses listed above are legitimate componentsof subsistence, when exploring the economicimportance of subsistence activities, researchersfrequently emphasize the use as food. Duringthe 1990s, rural residents of Alaska harvestedan average of 375 lb of wild foods per capita peryear (Wolfe 2000). In communities surveyed bythe ADF&G in the 1980s and 1990s, 75−98% ofthe households harvested fish and 92−100%used fish, and 48−70% harvested wildlife and79−92% used wildlife. Subsistence resourcesmeet most or all of the caloric and proteinrequirements in many rural communities (Wolfe1996). In addition, subsistence plays animportant role in the sociocultural systems ofAlaska Natives and many rural non-NativeAlaskans. Subsistence provides a basis for theexchange of important resources and for theestablishment and maintenance of socialnetworks, group leadership (such as coordinatedhunting and fishing), and ceremonial activities(such as potlatches) that help to knit societiestogether (e.g., Elanna and Sherrod 1984). Given

the importance of subsistence to manyAlaskans, it is easy to understand their high levelof concern with any activities that might disruptor otherwise compromise subsistence activities.

Certain types of development seem to createconditions that reduce subsistence productivity(Wolfe and Walker 1987). In general,subsistence harvests tend to increase in areas(1) that are more distant from urban settings,(2) that are unconnected by roads to urbansettings, (3) in which fewer nonlocals entersettlements, and (4) in which residents havelower average personal incomes. Proximity tourban settings tends to provide access toalternative sources of economic activity andresources, reducing the need to rely onsubsistence as a source of food and othermaterials. Connection by roads also helps toprovide access to alternative means of survival.Moreover, roads often result in large numbers ofnonlocals entering settlements, the introductionof competitors for wild resources, and theprecursors to habitat alteration. The relationshipbetween development and subsistence clearly iscomplex; in some cases, alternative economicopportunities lead people consciously to reducesubsistence activity; in other cases, competitionor habitat destruction force the reduction ofsubsistence activity.

This appendix presents a detailedexamination of subsistence patterns in areaspossibly affected by renewing the Federal Grantof ROW for TAPS. It begins with an examinationof subsistence in Alaska and the differentapproaches used by the federal government andAlaska state government to regulate this activity.It then examines subsistence activities in severalcommunities that are likely to be impacted by theTAPS by virtue of their proximity to it and forwhich subsistence data exist.

APPENDIX D D-4

D.2 Subsistence in Alaskain 2002

Subsistence in Alaska is an important,complex topic. The locations and numbers ofharvested resources vary greatly over time andspace. Moreover, subsistence activities aremanaged by two entities. The FederalSubsistence Board manages subsistence onfederal lands, and the Alaska State Boards ofFisheries and Game manage subsistence onstate lands. The situation in 2002 is the latestpart of an evolving history of events and issuesrelated to subsistence recognition andmanagement. Understanding key parts of thishistory can provide some important insights onthe nature of state subsistence data and onsubsistence concerns associated with thepossible continuance of the TAPS ROW. Anabbreviated list of key events in the history ofsubsistence management, and selectedcomponents of these events, follows (UnitedFishermen of Alaska 2002).

• 1925: Alaska Game Law states that anyAlaska Native, prospector, or traveler inneed of food can harvest any animal.

• 1959: Alaska becomes a state, adopting aconstitution that reserves fish and wildliferesources for �common use� by Alaskans.

• 1960: Federal authorities transfer fish andgame management to the newly formedstate government of Alaska.

• 1971: The Alaska Native Claims SettlementAct extinguishes Alaska Native hunting andfishing rights, but the conference reportnotes that aboriginal subsistence rights willbe protected by federal and state authorities.

• 1978: The Alaska legislature passes thestate�s first subsistence law, defining�subsistence� as customary and traditionaluses of fish and game for specific purposes,and establishing subsistence as the highest-priority use of fish and wildlife.

• 1980: Congress passes the Alaska NationalInterest Conservation Act (ANILCA) (16 USCSection 3120), with Title VIII establishing asubsistence priority for rural residents on

federal public lands. Title VIII also grants thestate the right to continue to managesubsistence on federal lands, providing itenacts a law establishing a subsistencepreference for rural residents.

• 1982: The Alaska State Boards of Fisheriesand Game adopt regulations establishing arural subsistence preference.

• 1989: The Alaska Supreme Court rules inMcDowell v. State that the rural priority forsubsistence violated the common use clauseof the state constitution, striking down part ofthe state subsistence law.

• 1990: The federal government(U.S. Department of the Interior [DOI] andU.S. Department of Agriculture [USDA])assumes management of subsistence onfederal public land (excluding navigablewaters).

• 1999: The federal government takes oversubsistence management of fisheries onnavigable waters associated with federalconservation lands.

As a result of the above sequence of events,subsistence still has priority over other uses ofresources throughout Alaska. Under federal law,only rural residents have the priority forsubsistence activities on federal land andnavigable waters. In contrast, under state law,any resident of Alaska may practice subsistenceon state lands. Although these differences inmanagement may appear to be of limited interestwith regard to this appendix, in fact, they greatlyconstrain any study of subsistence. In the briefhistory of events presented above, hunting andfishing have been managed in three differentways. First, from its statehood in 1959 through1978, the state of Alaska had no separatedefinition of subsistence. Then, from 1978 until1990, the state defined and managedsubsistence harvests on all lands. Finally, after1990, federal agencies defined and managedsubsistence harvests with separate regulationsfor federal lands and waters. Thus harvest datagenerated in any one of these periods are notnecessarily comparable to data generated inanother. For instance, since 1989/1990, anindividual from the city can be considered asport hunter (by definition) on federal land and

D-5 APPENDIX D

be considered a subsistence hunter only a short(walking) distance away on state land.

In addition to complicating the collection ofdata over time and the collection of data on stateversus federal land, the dual management ofsubsistence in Alaska affects what localities areexamined in this TAPS ROW Renewal EIS (andhence this appendix). Because the lead agencyin preparing this EIS is the BLM, this appendixuses the federal definition of subsistence with itsrural residency stipulation. The communitiesdiscussed in Section D.3 exclude those thatoccur in nonrural areas, as defined by theU.S. Fish and Wildlife Service (USFWS 2001).

D.3 Community-SpecificSubsistence-HarvestPatterns in theVicinity of the TAPS

D.3.1 Challenges in the Studyof Subsistence Patterns

At first glance, the study of subsistencewould seem to lend itself to the collection andanalysis of quantitative data. To a degree this istrue. However, subsistence patterns can varyconsiderably over space and time. Although it ispossible to deal with such variability, theresearch necessary requires the systematiccollection of data over many consecutive years,which were not available for subsistence inAlaska. The data presented here are useful forunderstanding the role of subsistence in severalcommunities that could be affected by therenewal of the Federal Grant for the TAPS ROW.They provide a sense of the number and amountof resources harvested, the proportion ofcommunity residents involved in their harvest,and the percentage of community residents whouse various resources. However, these datamust be considered in context; they provide onlya �snapshot� of community subsistence activitythat is changing constantly.

The main difficulty with the quantitativestudy of subsistence is the nature of the activityitself: it is an adaptation to available resources.The problem is that availability varies over time.

For example, various resources are seasonal,harvested when they become accessible(e.g., during salmon runs or caribou migrations)or desirable to harvest (e.g., when the coats ofcertain furbearers are of highest quality)(Figure D-1). These types of seasonal, timedsubsistence activities characterize all of thecommunities examined in this study.

Seasonal variability obviously does notaffect subsistence data that have been recordedfor an entire year, such as the data presented inSection D.3.3 below. However, the notion thatsubsistence involves the exploitation of availableresources introduces the potential for variabilitywhen availability changes from year to year. Asfish and animal populations fluctuate andmigration patterns change, harvests change aswell. Available data for annual harvests overmultiple years provide a sense of the degree ofvariability possible (Figure D-2). However, inmany communities, data are available for only asingle year. There is only one case among thecommunities considered in this study (ChenegaBay) in which data capture subsistence patternsfor as many as 5 consecutive years (ADF&G2001). The data presented in Section D.3.3provide an idea of the subsistence patterns thatoccur in an adaptive process that, by its nature,varies, and that, because of this variability,challenges the utility of any quantitativeinformation on harvest levels, participation, anduse (Nelson 1992).

Along with harvest levels, the geographicareas in which subsistence resources areobtained also vary over time. ThroughoutSection D.3.3, maps of subsistence harvestareas are presented (when data are available) toprovide a sense of the relationship betweenareas used for subsistence and the TAPS.Unfortunately, the same adaptation to availableresources that causes variability in harvestlevels over time also causes variability in harvestareas over time (Nelson 1992). The mapspresented in Figures D-5 through D-25 shouldtherefore be viewed as a general picture ofgeographic subsistence tendencies rather thanas maps with strict boundaries that remainunchanged year after year.

The data used in this appendix tocharacterize subsistence patterns ofcommunities near the TAPS were the best

APPENDIX D D-6

JanResource

Muskrat

Beaver

Marten

Lynx

Red Fox

Mink

Wolverine

Coyote

Wolf

Land Otter

Caribou

Moose

Black Bear

Porcupine

Hare

Geese/Ducks

Ptarmigan/Grouse

King Salmon

Sockeye Salmon

Silver Salmon

Grayling

Dolly Varden

Rainbow Trout

Lake Trout

Whitefish

Burbot

Berries

Other Plants

Intermittent

Wood

Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

JKA50206

1987-88 season closed; 1986-87 figures shown

FIGURE D-1 Example of the Seasonality of the Subsistence Harvest in Copper RiverBasin (Source: National Park Service 1995)

D-7 APPENDIX D

JKA50207

1996 1997

Year

Edi

ble

Pou

nds

Har

vest

ed

1998 1999

0

50

100

150

200

250

300

350

Large land mammals(mean)

Black Bear

Brown Bear

Caribou

Moose

Large land mammals(per capita)

Black Bear

Brown Bear

Caribou

Moose

FIGURE D-2 Changing Harvests over Time for Selected Resources in StevensVillage (Data Source: ADF&G 2001)

available. All the information presented is dated;some information was collected two decadesago. However, the inherent variability insubsistence, which constrains the utility ofsingle-year descriptions for characterizingsubsistence patterns, in a sense improves thevalue of older data for present purposes. Inmany cases, data on subsistence harvests in2001 would not represent typical subsistencepatterns any better than 1991 data. The mainexception to this statement might occur incommunities affected by the Exxon Valdez oilspill. However, in five communities examined(Chenega, Cordova, Nanwalek, Port Graham,and Tatitlek), the data presented were collectedwell after the 1989 spill, so they do provide asense of post-spill subsistence patterns.

D.3.2 Data Availability

This study examines subsistence at the levelof individual communities. The reasons for thislocalized focus are two: analytical necessity andpracticality. The former refers primarily to thetendency for different geographic settings in theenormous state of Alaska to offer very differentsubsistence resources. The subsistencepatterns of peoples both in the past and in thepresent reflect these differences (Hosley 1981),indicating the need to consider localizedsubsistence activities rather than larger regionalpatterns. Moreover, in addition to providing amore accurate view of subsistence patterns, afocus on individual communities enables thisstudy to focus on subsistence issues proximal to

APPENDIX D D-8

the TAPS. The second reason for a community-specific focus (i.e., practicality) refers to dataavailability. Ironically, for a topic as hotlydebated in Alaska as subsistence, actual data onsubsistence patterns are scarce. The best dataavailable were collected by the ADF&G throughdetailed subsistence surveys of individualcommunities (Fall 1990). This study relies onADF&G data for selected settlements in thevicinity of the TAPS.

This study first identified 44 communities inproximity of the TAPS for potential subsistenceanalysis. The communities of interest consistedof 21 largely Alaska Native villages identified bythe BLM as those that could be potentiallydirectly affected by the renewal of the FederalGrant for the TAPS ROW (BLM 2001) and 24communities geographically close to the TAPSthat were considered so that all places in thevicinity of the TAPS would be treated equally(Figure D-3). Three of the places consideredwere Native villages well west of Valdez. Theirinclusion reflected their proximity to areasaffected by the Exxon Valdez oil spill, theimpacts they experienced during that spill, andformal requests to be included within the EISprocess (Figure D-4).

This study does not examine subsistence forall 44 communities. As discussed in Section D.2,the EIS relies on federal guidelines that restrictsubsistence to rural residents of Alaska. Since10 of the 45 communities lie within the Fairbanks

North Star Borough Nonrural Area and one lieswithin the Valdez Nonrural Area (USFWS 2001),they were excluded from this study. Another10 communities meet the rural requirement butwere excluded because they have never beenthe subject of detailed subsistence surveys. Theremaining 24 communities are examinedbecause they meet the rural requirement andbecause some sort of subsistence data wereavailable for them (Table D-1).

D.3.3 Descriptions ofCommunity SubsistencePatterns

This section provides brief descriptions ofthe 24 communities examined in this study forwhich systematically collected subsistence dataexist. The aim is to provide key data in tabularand graphic (map) form, when possible,supplemented by a minimal amount of text, sothe reader can focus on key aspects of theinformation. For reader convenience, the text foreach community starts on a new page, followedby the appropriate table(s) and figure(s). Theemphasis of this data presentation is on fish,game, and other wild foods that are harvested.Although data on harvest levels for vegetablefoods and wood exist for many communities, thisappendix does not consider these resourcesbecause they are not typically felt to be affecteddirectly or indirectly by the TAPS.

D-9 APPENDIX D

Click here to view Figure D-3

FIGURE D-3 Communities Considered in the TAPS ROW Renewal EIS

D-11 APPENDIX D


FIGURE D-4 Geographic Extent of Exxon Valdez Oil Spill (Data Source: ADNR 1993)

D-13 APPENDIX D

TABLE D-1 Communities in Proximity to the TAPS, Demographic andSubsistence Overview

Community2000

Populationa Subsistence Survey Years Sources for Subsistence Datab

Alatnac35

1982d, 1983, 1984;1997, 1998, 1999

Marcotte and Haynes 1984; unpublishedADF&G and USFWS analyses

Allakaketc97

1982d, 1983, 1984;1997, 1998, 1999

Marcotte and Haynes 1984; unpublishedADF&G and USFWS analyses

Anaktuvuk Pass 282 1990, 1991, 1993d Unpublished ADF&G analyses

Big Delta 749 No survey conducted

Chenega86

1984, 1985, 1989, 1990,

1991, 1992, 1993d, 1997

Fall 1991; Fall and Utermohle 1995; Strattonand Chisum 1986; Stratton et al. 1996;unpublished ADF&G analysis

Chitina 123 1982, 1987d Fall and Stratton 1984; McMillan andCuccarese 1988; Stratton 1983; Stratton andGeorgette 1984, 1985; unpublished ADF&Ganalysis

Coldfoot 13 No survey conducted

Collegee 11,402 No survey conducted

Copper Center 362 1982, 1987d Fall and Stratton 1984; McMillan andCuccarese 1988; Stratton 1983; Stratton andGeorgette 1984, 1985; unpublished ADF&Ganalysis

Copperville 179 No survey conducted

Cordova/Eyak 2,454 1985, 1988, 1991, 1992,

1993, 1997dStratton 1989, 1992; Fall and Utermohle 1995;unpublished ADF&G analysis

Deadhorse 0f No survey conducted

Delta Junction 840 No survey conducted

Estere 1,680 No survey conducted

Evansville 28 1982d, 1983, 1984 Marcotte and Haynes 1984; unpublishedADF&G and USFWS analyses

Fairbankse 30,224 No survey conducted

Foxe 300 No survey conducted

APPENDIX D D-14

TABLE D-1 (Cont.)

Community2000


Gakona 215 1982, 1987d Fall and Stratton 1984; McMillan andCuccarese 1988; Stratton 1983; Stratton andGeorgette 1984, 1985; unpublished ADF&Ganalysis

Glennallen 554 1982, 1987d Fall and Stratton 1984; McMillan andCuccarese 1988; Stratton 1983; Stratton andGeorgette 1984, 1985; unpublished ADF&Ganalysis

Gulkana 88 1982, 1987d Fall and Stratton 1984; McMillan andCuccarese 1988; Stratton 1983; Stratton andGeorgette 1984, 1985; unpublished ADF&Ganalysis

Harding-Birch

Lakese216 No survey conducted

Hughes 78 1982d Marcotte and Haynes 1984

Kenny Lake 410 1982, 1987d Fall and Stratton 1984; McMillan andCuccarese 1988; Stratton 1983; Stratton andGeorgette 1984, 1985; unpublished ADF&Ganalysis

Livengood 29 No survey conducted

Manley Hot Springs 72 No survey conducted Betts 1997

Minto 258 1984d Andrews 1986

Moose Creeke 542 No survey conducted

Nanwalek 177 1987, 1989, 1990, 1991,

1992, 1993, 1997dFall 1991; Fall and Utermohle 1995;unpublished ADF&G analysis

North Polee 1,570 No survey conducted

Nuiqsut 433 1985, 1993d Fall and Utermohle 1995; unpublishedADF&G analysis

Paxson 43 No survey conducted

Pleasant Valleye 623 No survey conducted

Port Graham 171 No survey conducted

Prudhoe Bay 5 No survey conducted

D-15 APPENDIX D

TABLE D-1 (Cont.)

Community2000


Rampart 45 1993, 1994, 1995, 1996,1997

Betts 1997; unpublished ADF&G analysis

Salchae 854 No survey conducted

Stevens Village 87 1984, 1993, 1994, 1997 Betts 1997; Sumida 1988; Sumida andAlexander 1985; unpublished ADF&Ganalysis

Tanana 308 1987d, 1996, 1997, 1998,1999

Anderson 1992; Case and Halpin 1990; Betts1997; unpublished ADF&G analysis

Tatitlek 107 1987, 1988, 1989, 1990,

1991, 1993, 1997dFall 1991; Fall and Utermohle 1995; Strattonet al. 1996; unpublished ADF&G analysis

Tazlina 149 1987d McMillan and Cuccarese 1988; Stratton andGeorgette 1985; unpublished ADF&G analysis

Tonsina 92 1982, 1987d Fall and Stratton 1984; McMillan andCuccarese 1988; Stratton 1983; Stratton andGeorgette 1984, 1985; unpublished ADF&Ganalysis

Two Riverse 482 No survey conducted

Valdezg 4,036 No survey conducted

Wiseman 21 No survey conducted

a Data are from U.S. Bureau of the Census (2001).

b Data for survey years listed are as reported in ADF&G (2001).

c 1982, 1983, and 1984 subsistence survey data for Alatna and Allakaket are reported for both communitiescombined.

d Designated �representative year� by ADF&G.

e No subsistence data are reported because communities lie in Fairbanks North Shore Borough Nonrural Area(USFWS 2001).

f Officially, there are no permanent residents in Deadhorse. The population consists of about 5,000 transient oilworkers.

g No subsistence data are reported because Valdez lies in Valdez Nonrural Area (USFWS 2001).

APPENDIX D D-16

D.3.3.1 Alatna

Alatna is a small village located on the northbank of the Koyukuk River, immediately south ofits intersection with the Alatna River and about56 mi west of the TAPS (Figure D-3) (AlaskaDepartment of Community and EconomicDevelopment [ADCED] 2001). Alatna has itsroots as a trading location, with the Kobuk RiverIñupiat living on the north bank of the river andthe Koyukon Athabascans living on the southbank in modern-day Allakaket. The population ofAlatna in 2000 was 35, with the majority ofresidents being of Kubuk River Iñupiat heritage(Table D-1). Subsistence dominates theeconomic activity of the community,supplemented by a small amount of wage laborfrom seasonal work and the production of Nativecrafts.

Most of the subsistence data available forAlatna combine information on this village withdata on neighboring Allakaket (Northern LandUse Research, Inc. 2000b). The exception to

combined data is surveys of large land mammalharvests in 1997, 1998, and 1999. Table D-2presents results of the 1998 survey, whichrecorded harvest for caribou and moose alone.Table D-3, in turn, presents 1982 subsistenceharvest data for a broader range of resources,but for Alatna combined with Allakaket (Marcotteand Haynes 1984). Subsistence activitiesreported in the latter table involved a variety ofland mammals, birds, and fish, with the latterbeing of particular importance. Householdparticipation rates for harvests varied widely byresource, with 70% of Alatna householdsharvesting large game in 1998 and 100% ofcommunity households using those resources.The subsistence harvest area for Alatnaoccurred west of the TAPS, though it includedpart of Koyukuk River downstream of thepipeline (Figure D-5). Concerns identified duringthe late 1990s included both competition fromnonlocal hunters and declining numbers ofmoose and caribou. The latter problem wasblamed on hunting competition and predation bywolves (ADF&G 2001).

TABLE D-2 Subsistence Harvest Summary for Alatna in 1998a

Edible Pounds HarvestedPercent of Households

Surveyed

Subsistence Resource

Units,Total

Harvested TotalHousehold

Harvest MeanPer

CapitaHouseholdsHarvesting

HouseholdsUsing

Terrestrial MammalsLarge land mammal 16 4,130 413.0 153.0 70.0 100.0 Moose 5 2,700 270.0 100.0 60.0 100.0 Caribou 11 1,430 143.0 53.0 30.0 100.0

a Number of households in sample was 10; number of households in community was 10.

Source: ADF&G (2001) (sums corrected or inserted as necessary).

D-17 APPENDIX D


FIGURE D-5 Subsistence Harvest Areas Associated with Alatna (Data Source:ADF&G undated)

D-19 APPENDIX D

TABLE D-3 Subsistence Harvest Summary for Allakaket/Alatna in 1982a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 66 18,044 462.7 118.2 NAb NA Black bear 23 1,357 34.8 8.9 37.1 NA Caribou 6 724 18.6 4.7 5.7 NA Dall sheep 6 362 9.3 23.7 11.4 NA Moose 31 15,600 400.0 102.2 77.1 NASmall land mammal/furbearerc 2,895 3,622 92.9 23.8 NA NA Beaver 256 2,255 57.8 14.8 65.7 NA Foxd 99 −e − − 34.3 NA Hare 911 1,367 35.1 9.0 80.0 NA Land otterd 4 − − − 5.7 NA

Lynxd 150 − − − 54.0 NA

Martend 1,195 − − − 80.0 NA

Muskratd 140 − − − 31.4 NA

Wolfd 2 − − − 5.7 NA

Wolverined 4 − − − 11.4 NA

FishesTotal fish 24,187 111,689 2,863.9 731.7 NA NA Total salmon 13,170 84,641 2,170.3 554.5 NA NA Total non-salmon 11,017 27,048 693.6 177.2 NA NA Burbot 65 155 4.0 1.0 8.6 NA Grayling 1,826 1,278 32.8 8.4 54.3 NA Pike 447 1,252 32.1 8.2 40.0 NA Sheefish 2,731 19,118 490.2 125.2 68.6 NA Sucker 535 374 9.6 2.5 37.1 NA Whitefish 5,413 4,871 124.9 31.9 71.2 NA

BirdsTotal bird and egg 1,658 3,766 96.6 24.7 NA NA Migratory bird 1,396 3,635 93.2 23.8 NA NA Duck 956 1,434 36.8 9.4 80.0 NA Goose 440 2,201 56.4 14.4 77.1 NA Upland game bird 262 131 3.4 0.9 NA NA Grouse 90 45 1.2 0.3 37.1 NA Ptarmigan 172 86 2.2 0.6 45.7 NA

a Number of households in sample was 35; number of households in communities was 39.

b NA = data not available.

c Some not eaten.

d Not eaten.

e �−�= 0 or a number that rounds to 0.

Source: ADF&G (2001) (sums corrected as necessary).

APPENDIX D D-20

D.3.3.2 Allakaket

Allakaket, a rural village consisting primarilyof Koyukon Athabascans, lies on the south bankof the Koyukuk River roughly 55 mi west of theTAPS (Figure D-3) (ADCED 2001). As noted forAlatna, Allakaket occurs at an important tradinglocality on the Koyukuk, particularly forexchange with the neighboring Kobuk RiverIñupiat in Alatna. In 2000, the population of thisvillage was 97 (Table D-1). The economy ofAllakaket relies heavily on subsistence,complemented with wage labor that is primarilyseasonal or part time.

Subsistence in Allakaket relies on largeamounts of both land mammals and fish(Marcotte and Haynes 1984; Brannian andGnath 1988). As they did for Alatna, harvest datafor Allakaket alone in 1998 covered large landmammals only (Table D-4). The data indicatethat the majority of the households surveyed

harvested these animals and that virtually allhouseholds used them. Data from the specifiedrepresentative year of 1982 combined Allakaketwith Alatna. They indicate reliance on a widerange of resources (Table D-3). Although fishaccounted for the greatest amount ofsubsistence resources in 1982, harvests of largeand small land mammals and certain birdstended to be higher then. Concerns related tosubsistence identified during the late 1990sincluded competition from nonlocal hunters anddeclining numbers of moose and caribou. Thelatter problem was blamed on huntingcompetition and predation by wolves (ADF&G2001). Subsistence concerns expressed byAllakaket residents during public scoping for theTAPS EIS included impacts from the TAPS oncaribou migration patterns, competition fromnonlocal hunters and fishermen, airboatsdisrupting fish spawning grounds, and tourismdisrupting subsistence harvests (Moses 1993).

TABLE D-4 Subsistence Harvest Summary for Allakaket in 1998a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 91 26,496 434.4 138.9 58.2 100.0 Black bear 11 1,109 18.2 5.8 12.7 98.2 Caribou 43 5,623 92.2 29.5 25.5 100.0 Moose 37 19,764 324.0 103.6 50.9 100.0


Source: ADF&G (2001).

D-21 APPENDIX D

D.3.3.3 Anaktuvuk Pass

Anaktuvuk Pass, the last remainingsettlement of the Nunamiut, lies in the centralBrooks Range about 49 mi west of the TAPS(Figure D-3) (ADCED 2001). Beginning in themid-19th century, these interior Iñupiat beganleaving the various valleys they inhabited in theBrooks Range to move to the north coast. Theinitial attraction was the availability of varioustrade goods from whalers. However, declines inthe Western Arctic caribou herd around 1900and disease contributed to the Iñupiat relocation(Gubser 1965). With the resettlement ofAnaktuvuk Pass in the late 1940s, the trendbegan to reverse, and by 2000, the villagepopulation had grown to 282 (Table D-1). Due inpart to geographic isolation, subsistence is themain economic activity in this community,supplemented by predominantly part-time andseasonal wage employment both in the villageand elsewhere (ADCED 2001; North SlopeBorough 1999).

The dominant subsistence resource inAnaktuvuk Pass is caribou, the sole subject ofADF&G subsistence surveys in 1990, 1991, and1993 (ADF&G 2001). Survey data from 1993indicate that nearly 43% of Anaktuvuk Passhouseholds participated in caribou hunting(Table D-5). Anecdotal data indicate that allhouseholds share in the consumption of thisresource (e.g., Mekiana 1992). Other dataindicate that a range of other species alsoplayed a role in Anaktuvuk Pass subsistence,including sheep, grizzly bear, moose, groundsquirrel, marmot, wolf, wolverine, ptarmigan,grayling, lake trout, lingcod, and whitefish(Spearman et al. 1979). Part of the subsistenceharvest area recorded for Anaktuvuk Passoverlaps with the TAPS (Figure D-6).Subsistence concerns identified during the early1990s revolved around the lack of cariboumigration through the pass in 1989, as a result ofnonlocal subsistence and sport hunting and theconstraints on subsistence hunting within Gatesof the Arctic National Park and Preserve(ADF&G 2001; Mekiana 1992).

TABLE D-5 Subsistence Harvest Summary for Anaktuvuk Pass in 1993a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 574 67,713 84,641 219.4 42.5 NAb

Caribou 574 67,713 84,641 219.4 42.5 NA




APPENDIX D D-22

D-23 APPENDIX D


FIGURE D-6 Subsistence Harvest Areas Associated with Anaktuvuk Pass (DataSource: ADF&G undated)

D-25 APPENDIX D

D.3.3.4 Chenega Bay

Chenega Bay is a small, unincorporatedcommunity located on Evans Island in PrinceWilliam Sound roughly 85 mi southwest of theValdez Marine Terminal (Figure D-3) (ADCED2001). The original Alutiiq village of ChenegaBay, located at the southern tip of ChenegaIsland, was destroyed by the 1964 earthquake.The current location was settled in 1984. TheChenega Bay economy is mixed, combiningsubsistence, commercial fishing, and small-scale oyster farming (Tomrdle and Miraglia1993). The absence of cash employmentopportunities may account for the decline inpopulation over the past decade; it decreasedfrom 94 in 1990 to 86 in the 2000 census(Table D-1; ADCED 2001).

The residents of Chenega Bay harvest awide range of land and marine mammals, fish,birds, and marine invertebrates for subsistencepurposes (Table D-6) (Fall and Utermohle 1995;Stratton and Chisum 1986). Marine resourcesplay a particularly important role. More than 95%of the households were found to be involved insubsistence fishing, and all householdsconsumed fish. Nearly 74% of surveyedhouseholds collected marine invertebrates, and

more than 91% of the households consumedresources in this category. Chenega Bayresidents also obtained and used marinemammals (particularly seals), although at lowerrates than they obtained and used fish andinvertebrates. On the basis of 1984−1986 data(pre-Exxon Valdez oil spill), per capita harvestsappear to have declined substantially (42%)from levels in the 1960s. Reasons proposed forthe decline included changing regulations andreduced resource levels (Stratton and Chisum1986). Traditional subsistence harvest areas forChenega Bay occur primarily in western PrinceWilliam Sound, more than 50 mi west of theValdez Marine Terminal, but small harvest areasalso occur closer to the south and east of theterminal (Figure D-7) (see also Ganley 2001;Ganley and Wheeler 2000). Persisting effects(contamination) of the Exxon Valdez oil spill;shortages of seals, sea lions, clams, octopus,and some ducks; certain regulations affectingsubsistence harvests of salmon; and competitionfor deer by nonlocal and recreational huntershave been cited as considerations. Datacollected after the Exxon Valdez spill suggestthat concern about that event continues and thatsubsistence harvests declined substantially forseveral years following the 1989 spill (Fall1999).

APPENDIX D D-26

TABLE D-6 Subsistence Harvest Summary for Chenega Bay in 1993a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Marine MammalsMarine mammal 85 3,528 126.0 34.9 43.5 56.5

Sea otter 6 −b − − 8.7 13.0 Seal 67 2,531 90.4 25.1 39.1 56.5 Steller sea lion 12 997 35.6 9.9 26.1 43.5

Terrestrial mammalsLarge land mammal 38 1,796 64.2 17.8 47.8 82.6 Black bear 2 141 5.0 1.4 8.7 17.4 Caribou 1 183 6.5 1.8 4.3 8.7 Deer 34 1473 52.6 14.6 47.8 82.6

Small land mammal/furbearerc 13 49 1.7 0.5 13.0 13.0

Land otterd 7 − − − 8.7 8.7 Porcupine 6 49 1.7 0.5 4.3 4.3

Fishes and Marine InvertebratesTotal fish 19,980 19,980 713.6 197.7 95.7 100.0 Total salmon 2,686 10,985 392.3 108.7 69.9 95.7 Total non-salmon 8,994 8,994 321.2 89.0 56.5 95.7 Char 61 85 3.0 0.8 21.7 21.7 Cod 315 1,005 35.9 10.0 17.4 43.5 Greenling 252 343 12.3 3.4 21.7 26.1 Halibut 82 3,686 131.7 36.5 52.2 91.3

Herring 73e 40 1.4 0.4 8.7 26.1

Herring roe 5e 34 1.2 0.3 4.3 30.4 Rockfish 1,084 3,229 115.3 32.0 4.35 73.9 Sablefish 180 558 19.9 5.5 8.7 26.1 Shark 1 11 0.4 0.1 4.3 4.3 Wolffish 5 2 − − 8.7 8.7

Marine invertebrate 1,498 1,498 53.5 14.8 73.9 91.3 Chiton 21 83 3.0 1.0 34.8 47.8 Clam 94 283 10.1 2.8 52.2 65.2 Crab 15 23 0.8 0.2 4.3 8.7 Mussel 4 13 0.5 0.1 13.0 13.0 Octopus 255 1,020 36.4 10.1 34.8 60.9 Oyster 1 4 0.1 - 4.3 4.3 Shrimp 36 71 2.5 0.7 17.4 60.9

BirdsTotal bird and egg 168 151 5.4 1.5 43.5 52.2 Migratory bird 85 106 3.8 1.1 26.1 30.4 Duck 72 60 2.2 0.6 26.1 26.1 Goose 13 46 1.6 0.5 8.7 13.0

D-27 APPENDIX D

TABLE D-6 (Cont.)


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Upland game bird 63 44 1.6 0.4 26.1 30.4 Grouse 63 44 1.6 0.4 26.1 30.4 Bird eggs 19 1 − − 4.3 8.7


b �−� = 0 or a number that rounds to 0.

c Some not eaten.

d Not eaten.

e Unit of measure is gallon.


APPENDIX D D-28

D-29 APPENDIX D


FIGURE D-7 Subsistence Harvest Areas Associated with Chenega Bay (DataSource: ADF&G undated)

D-31 APPENDIX D

D.3.3.5 Chitina

The village of Chitina lies on the west bankof the Copper River near its confluence with theChitina River, about 21 mi east of the TAPS(Figure D-3) (ADCED 2001). Likely a home toCopper River Athabascans for centuries, themodern community of Chitina emerged as oneterminus of a railroad to the Kennicott CopperMine in the early 1900s. Chitina�s populationgrew rapidly, then plummeted when minesupport was relocated to Glennallen in 1938.The 2000 census recorded 123 residents inChitina (Table D-1). The village economy ismixed. Although most village residents practicesubsistence year-round, the location of Chitinanear the Richardson Highway provides bothyear-round and seasonal wage employmentopportunities for many village residents toaugment subsistence (Stratton and Georgette1984).

Fishing played a particularly important rolein the village subsistence economy in terms ofpounds of harvest yielded, participation (nearly78% of households), and use (more than 94% ofhouseholds) in the reference year of 1987(Table D-7) (Fall et al. 2001; National ParkService 1995). Salmon was by far the mostimportant subsistence resource. Of terrestrialresources, caribou contributed the greatestamount of meat and other material to the Chitinaeconomy. Part of the Chitina traditionalsubsistence harvest area overlaps with theTAPS; the primary subsistence activity ishunting, which extends along the pipeline(Figure D-8). Long portions of the Copper Riveralso occur in the subsistence harvest areadownstream of the TAPS, although only smallportions involve fish (salmon) harvests.Subsistence concerns identified during the1980s included hunting and fishing bag limits(particularly on caribou and salmon) and boththe potential increased competition for resourcesand habitat destruction due to development inthe area (ADF&G 2001).

APPENDIX D D-32

TABLE D-7 Subsistence Harvest Summary for Chitina in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 6 1,837 96.7 52.7 27.8 50.0 Caribou 3 412 21.7 11.8 11.1 16.7 Moose 3 1,425 75.0 40.9 16.7 27.8

Small land mammal/furbearerb 178 279 14.7 8.0 44.4 50.0 Hare 173 260 13.7 7.5 38.9 44.4

Martenc 1 −d − − 5.6 5.6 Porcupine 4 19 1.0 0.6 22.2 22.2

FishesTotal fish 9,239 9,239 486.2 265.3 77.8 94.4 Total salmon 1,726 8,337 438.8 239.4 61.1 72.2 Total non-salmon 902 902 47.5 25.9 61.1 83.3 Burbot 26 63 3.3 1.8 11.1 11.1

Char 117 152 7.9 4.4 16.7e 16.7e

Grayling 258 180 9.5 5.2 33.3 33.3 Halibut 53 53 2.8 1.5 11.1 38.9 Trout 257 359 18.8 10.3 33.3 50.0 Whitefish 106 95 5.0 2.7 5.6 66.7

BirdsTotal bird and egg 110 61 3.2 1.8 33.3 33.3 Migratory bird 26 19 1.0 0.6 5.6 5.6 Duck 24 17 0.9 0.5 5.6 5.6 Goose 2 2 0.1 0.1 5.6 5.6 Upland game bird 83 42 2.2 1.2 33.3 33.3 Grouse 83 42 2.19 1.21 33.3 33.3


b Some not eaten.

c Not eaten.

d �−� = 0 or a number that rounds to 0.

e Data not recorded; value reported is the maximum of those recorded for subcategories.


D-33 APPENDIX D


FIGURE D-8 Subsistence Harvest Areas Associated with Chitina (Data Source:ADF&G undated)

D-35 APPENDIX D

D.3.3.6 Copper Center

Copper Center is located on the westernbank of the Copper River, where it joins theKlutina River, only 0.6 mi east of the TAPS(Figure D-3) (ADCED 2001). A desirable locationat the confluence of two important rivers, the siteoccupied by Copper Center has a long history ofprehistoric and historic settlement. The moderncommunity of Copper Center has its roots largelyin the gold rush and subsequent development ofthe Kennicott Copper Mine, beginning in the late1800s. By 2000, 362 people resided in CopperCenter (see Table D-1). The Copper Centereconomy is mixed. Many residents of CopperCenter are involved in wage labor; they areemployed in a variety of local services,businesses, the National Park Service offices forWrangell-St. Elias National Park, and highway-related tourism. A number of Copper Centerresidents also practice subsistence, although therole of this activity is not as important as it is inother communities because a range of economicalternatives exist.

Subsistence activities in Copper Centerinvolved a variety of terrestrial and riverineresources in 1987 (Table D-8) (Fall et al. 2001;Stratton and Georgette 1984; see also NationalPark Service 1995; Simeone and Fall 1996).Fish, notably salmon, was the most importantresource in terms of edible pounds per capita;more than 90% of the households surveyed usedsalmon. Caribou and moose each contributedabout the same amount of edible pounds percapita, between about 26 and 28 lb, respectively;birds and small game provided much less. Aconsiderable amount of the traditionalsubsistence harvest area for Copper Centeroverlaps with the TAPS. This overlapping areainvolves a range of terrestrial and riverinelocalities and includes a large section of theCopper River downstream from the pipeline,although much of the river area primarilyinvolves moose hunting (Figure D-9).Subsistence concerns identified during the1980s included hunting and fishing bag limits(particularly on caribou and salmon), and bothpotential increased competition for resourcesand habitat destruction due to development inthe area (ADF&G 2001).

APPENDIX D D-36

TABLE D-8 Subsistence Harvest Summary for Copper Center in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 153 28,338 176.0 57.5 51.8 78.1 Caribou 100 12,942 80.4 26.3 48.0 72.8 Goat 8 546 3.4 1.1 4.7 4.7 Moose 31 13,870 86.2 28.2 19.1 53.1 Dall sheep 15 979 6.1 2.0 4.7 9.4Small land mammal/furbearerb 237 405 2.3 0.8 27.1 38.7 Beaver 4 67 0.4 0.1 0.7 13.9

Foxc 13 −d − − 6.1 6.1 Hare 112 169 1.1 0.3 6.9 17.9 Martenc 11 − − − 5.4 5.4 Porcupine 38 170 1.1 0.4 18.8 18.8 Squirrelc 33 − − − 0.7 0.7 Weaselc 24 − − − 6.1 6.1

FishesTotal fish 54,323 54,323 337.4 110.3 78.1 90.6 Total salmon 10,215 51,006 316.8 103.5 68.1 90.0 Total non-salmon 3,317 3,317 20.6 6.7 57.8 78.1 Halibut 739 739 4.6 1.5 4.5 28.7 Rockfish 20 81 0.5 0.2 1.6 1.6 Burbot 125 300 1.9 0.6 10.1 21.7 Char 476 593 3.7 1.2 - 13.9e

Grayling 1,537 1,076 6.7 2.2 47.4 55.2 Sucker 6 4 0.0 0.0 0.7 0.7 Trout 158 435 2.7 0.9 - 8.4e

Whitefish 98 88 0.6 0.2 3.0 18.4

BirdsTotal bird and egg 1,007 711 4.4 1.4 34.0 42.5 Migratory bird 244 329 2.0 0.7 6.3 6.3 Duck 184 130 0.8 0.3 6.3 6.3 Goose 45 108 0.7 0.2 4.7 4.7 Crane 15 90 0.6 0.2 4.7 4.7 Upland game bird 763 382 2.4 0.8 34.0 42.5 Grouse 607 303 1.9 0.6 29.3 36.3 Ptarmigan 156 78 0.5 0.1 12.3 20.1


b Some not eaten.

c Not eaten.




D-37 APPENDIX D


FIGURE D-9 Subsistence Harvest Areas Associated with Copper Center (DataSource: ADF&G undated)

D-39 APPENDIX D

D.3.3.7 Cordova (and Eyak)

Cordova is a small community located about35 mi south-southeast of the TAPS, in theeastern part of Prince William Sound(Figure D-3) (ADCED 2001). Although it was thelocation of Alutiiq settlements for centuries, themodern community was not founded until 1909,when it became the southern terminus of theCopper River and Northwest Railroad. Eyak, oneof the 21 directly affected communities identifiedby the BLM (2001), is a small community lyingabout 5 mi southeast of Cordova. Also originallyan Alutiiq settlement, Eyak has been moreperipheral to development in eastern PrinceWilliam Sound than Cordova. Eyak was annexedby the city of Cordova in 1992. The population ofCordova was 2,454 in 2000, while that of Eyakwas 168 in the same year (see Table D-1).

Much of the economy of Cordova is wage-based, reliant primarily on commercial fishingand fish processing (ACDED 2001). Somesubsistence activities also occur in Cordova, butthey largely serve to supplement wage labor.The economy of Eyak also relies a great deal onwage labor, including commercial fishing, fishprocessing, the timber industry, and otheremployment (largely in Cordova). ADF&Gconducted subsistence studies in Cordova in

1985, 1988, 1991, 1992, 1993, and 1997(ADF&G 2001). ADF&G conducted no suchstudies of Eyak. As a result, one must rely onpatterns recorded for Cordova as a generalindicator for patterns in its smaller neighbor(Stratton 1992; Tomrdle and Miraglia 1993).

Given the levels of wage employment,subsistence does not play an extremelyimportant role in the Cordova economy. As it isin other coastal communities, the range ofresources harvested in Cordova is quite broad;more than 100 species were used in 1992(Stratton 1992). Harvest levels seem to be lowerhere than they are in other communities onPrince William Sound that have relatively largeAlaska Native populations, such as ChenegaBay and Tatitlek. Fishing was by far the mostimportant subsistence activity in Cordova in1997, contributing more than 105 lb per capitaand involving nearly 94% of the householdssurveyed (see Table D-9). Hunting large landmammals also involved a relatively largepercentage of the Cordova population (77.1% ofsurveyed households), with deer and mooseeach contributing more than 21 lb per capita tothe diet. Subsistence concerns that wereidentified included contamination andenvironmental damage associated with theExxon Valdez oil spill in 1989 (Fall 1999).

APPENDIX D D-40

TABLE D-9 Subsistence Harvest Summary for Cordova in 1997a


Surveyed

Subsistence ResourceUnits, TotalHarvested Total

HouseholdHarvest Mean

PerCapita

HouseholdsHarvesting

HouseholdsUsing

Marine MammalsMarine mammalb 391 9,114 11.0 3.6 5.1 11.0

Sea otterc 179 −d − − 3.5 5.5

Seal 212 9,114 11.0 3.6 3.5 8.6

Terrestrial MammalsLarge land mammal 1,043 131,308 158.2 52.4 47.4 77.1 Black bear NAe 2,473 3.0 1.0 4.7 11.8

Brown bear 26 1,972 2.4 0.8 2.4 2.4 Caribou 13 1,972 2.4 0.8 0.8 7.1 Dall sheep 7 684 0.8 0.3 0.8 4.0 Deer 1,441 62,248 75.0 24.8 40.7 72.7 Elk 26 5,917 7.1 2.4 2.4 2.8 Goat 36 2,860 3.5 1.1 4.0 9.5 Moose 98 53,182 64.1 21.2 10.7 49.4

Small land mammal/furbearerb 3,304 5,304 6.4 2.1 26.5 30.0 Beaver 145 345 0.4 0.1 3.2 3.6

Coyotec 49 − − − 2.8 3.6 Hare 2,443 4,887 5.9 2.0 22.1 24.5

Land otterc 118 − − − 3.6 3.6

Lynxc 3 − − − 0.4 0.4

Martenc 108 − − − 5.1 5.1

Minkc 174 − − − 4.0 4.7

Muskratc 72 − − − 2.4 2.4

Porcupine 7 53 0.1 - 0.8 2.0

Squirrelc 118 20 − − 2.4 2.4

Weaselc 59 − − − 1.6 1.6

Wolverinec 7 − − − 0.8 0.8

Terrestrial MammalsTotal fish 263,712 263,712 317.7 105.2 75.1 93.7 Total salmon 23,061 156,875 189.0 62.6 66.0 88.5 Total non-salmon 106,838 106,838 128.7 42.6 58.5 84.6 Bass 642 642 0.8 0.3 4.4 6.7 Char 1,388 1,943 2.3 0.8 14.2 14.6 Cod 841 2,265 2.7 0.9 11.9 20.2 Grayling 273 191 0.2 0.1 2.8 2.8 Greenling 633 1,202 1.5 0.5 13.4 19.8 Halibut 66,450 66,450 80.1 26.5 44.3 82.6

Herringf 831 4,985 6.0 2.0 11.5 13.4

Herring roef 267 1,870 2.3 0.1 4.3 9.1 Rockfish 4,408 12,360 14.9 4.9 22.1 39.5 Sablefish 625 1,936 2.3 0.8 5.1 18.2

D-41 APPENDIX D

TABLE D-9 (Cont.)


Surveyed



PerCapita


HouseholdsUsing

Sculpin 85 43 0.1 − 2.4 2.4

Skate 7 33 − − 0.4 0.4

Smeltf 2,889 9,389 11.3 3.7 19.3 31.6 Sole 134 134 0.2 - 3.2 4.0 Sturgeon 7 224 0.3 0.1 0.8 0.8 Trout 2,113 2,958 3.6 1.2 21.3 27.3 Wolffish 13 7 − − 1.6 2.0

Marine invertebrate 13,844 13,844 16.7 5.5 29.2 51.7

Chitonf 2 7 − − 0.8 1.6

Clamf 1,503 4,510 5.4 1.8 24.9 38.3

Cocklef 5 15 − − 0.8 1.2

Crab 4,909 7,656 9.2 3.0 7.5 28.4

Geoduckf 12 37 − − 0.4 0.4

Limpetf 13 20 − − 0.8 0.8

Musself 26 40 − − 3.2 4.7 Octopus 43 170 0.2 0.1 1.6 12.2 Shrimp 995 995 1.2 0.4 9.1 18.2 Squid 197 394 0.5 0.2 0.8 5.1

Birds and Bird EggsTotal bird and egg 7,852 5,593 6.7 2.2 30.4 42.3 Migratory bird 5,091 4,056 4.9 1.6 24.1 36.8 Crane 20 165 0.2 0.1 2.0 3.6 Duck 4,708 3,274 3.9 1.3 22.5 35.2 Goose 269 598 0.7 0.2 6.3 8.3 Seabird and loon 3 10 - - 0.4 0.4 Shorebird 92 9 - - 3.2 3.2 Upland game bird 1,830 1,281 1.5 0.5 22.5 24.9 Grouse 1,017 712 0.9 0.3 17.8 19.0 Ptarmigan 813 569 0.7 0.2 14.2 15.4 Bird egg 925 252 0.3 0.1 2.4 4.7

See next page for footnotes.

APPENDIX D D-42

TABLE D-9 (Cont.)


b Some not eaten.

c Not eaten.


e NA = data not available. Value in data table appears to be incorrect for black bear; total for large land mammalsreflects inclusion of this value, but this value is not included under the number of black bears harvested for1997.

f Unit of measure is gallon.


D-43 APPENDIX D

D.3.3.8 Evansville

Evansville is an interior village located onthe south bank of the Koyukuk River about 22 miwest of the TAPS (Figure D-3) (ADCED 2001).Evansville and the neighboring community ofBettles were born in the 1940s when an airfieldwas built to support exploration of the NavalPetroleum Reserve No. 4 (Northern Land UseResearch, Inc. 2000b). Construction of theairfield attracted both Alaska Natives and non-Natives to the area, with the former settlingprimarily in Evansville (near the northern end ofthe airfield) and the latter settling mostly inBettles (near the southern end of the airfield).The decennial census in 2000 recorded 28people in Evansville (Table D-1). In contrast toresidents of most rural communities in Alaska,many Evansville residents are engaged in wagelabor; most jobs are associated with airtransportation, visitor services, and the local andfederal government.

Subsistence activities, such as hunting,fishing, and trapping, help to supplement wagelabor in Evansville (Marcotte and Haynes 1984).For most of the past two decades, subsistencestudies have combined data on Evansville withdata on nearby Bettles. Exceptions are 1997,1998, and 1999, when studies examined largegame harvests in Evansville (ADF&G 2001).

Evansville-specific data for 1998 indicate thatlarge game contributed fewer than 84 edible lbper capita to village residents (Table D-10).Nevertheless, although only about one-third ofthe households surveyed actually huntedcaribou or moose, nearly 92% used theseresources, an indication of how much exchangeinvolving these two resources occurred.Subsistence data for Bettles and Evansvillecombined indicate that large game providednearly 135 edible lb per capita and that fishcontributed nearly as much, at 107 edible lb perresident of the two communities (Table D-11).Trapping also was important in 1982, although itcontributed little meat and was probably done toobtain skins to sell. Part of the subsistenceharvest area for Bettles/Evansville overlaps witha sector of the TAPS (Figure D-10).

Subsistence concerns identified during theearly 1980s for both communities includedincreased competition for subsistence resourcesdue to improved access, sporadic cariboumigration (no reason proposed), and low moosepopulations (in 1987, again with no reasonsproposed) (ADF&G 2001). Restrictions onsubsistence in Gates of the Arctic National Parkand Preserve were cited as a problem in theearly 1990s (Holly 1992), and competition withnonlocal hunters was cited in 1997 and 1999(ADF&G 2001).

TABLE D-10 Subsistence Harvest Summary for Evansville in 1998a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 8 2,345 167.5 83.8 33.3 91.7 Caribou 4 455 32.5 16.3 16.7 66.7 Moose 4 1,890 135.0 67.5 25.0 91.7



APPENDIX D D-44

TABLE D-11 Subsistence Harvest Summary for Bettles/Evansville in 1982a,b


Surveyed



PerCapita


HouseholdsUsing

Terrestrial MammalsLarge land mammal 37 8,740 349.6 134.5 NAc NA

Black bear 6 363 14.5 5.6 25.0 NA

Brown bear 1 176 7.1 2.7 5.0 NA

Caribou 14 1,788 71.5 27.5 15.0 NA

Dall sheep 3 163 6.5 2.5 5.0 NA

Moose 13 6,250 250.0 96.2 35.0 NA

Small land mammal/furbearerd 585 555 22.3 8.6 NA

Beaver 14 121 4.9 1.9 15.0 NA

Coyotee 1 −f − − 5.0 NA

Foxe 25 − − − 20.0 NA

Haree 289 434 17.4 6.7 35.0 NA

Lynxe 38 − − − 30.0 NA

Martene 193 − − − 25.0 NA

Muskrate 16 − − − 15.0 NA

Wolverinee 9 − − − 15.0 NA

FishesTotal fish 1,910 6,979 279.2 107.3 NA NA

Total salmon 676 4,260 170.4 65.5 25.0g NA Total non-salmon 1,234 2,718 108.8 41.7 NA NA Grayling 614 430 17.2 6.6 70.0 NA Pike 16 45 1.8 0.7 15.0 NA Sheefish 265 1,855 74.2 28.5 20.0 NA Trout 76 152 6.1 2.3 15.0 NA Whitefish 263 236 9.5 3.6 10.0 NA

BirdsTotal bird and egg 94 159 6.4 2.6 NA NA Migratory bird 60 143 5.7 2.3 NA NA Duck 45 68 2.7 1.1 15.0 NA Goose 15 75 3.0 1.2 10.0 NA Upland game bird 34 16 0.7 0.3 NA NA Grouse 9 3 0.2 0.1 10.0 NA Ptarmigan 25 13 0.5 0.2 25.0 NA


D-45 APPENDIX D

TABLE D-11 (Cont.)


b Data reported for �Bettles/Evansville.� Data reported solely for Evansville (1997, 1998, and 1999) onlyreported large terrestrial mammal harvests and did not include a �representative year� for harvest levels.

c NA = data not available.

d Some not eaten.

e Not eaten.

f �−� = 0 or a number that rounds to 0.

g Data not recorded; value reported is the maximum of those recorded for subcategories.


APPENDIX D D-46

D-47 APPENDIX D


FIGURE D-10 Subsistence Harvest Areas Associated with Evansville (Data Source:ADF&G undated)

D-49 APPENDIX D

D.3.3.9 Gakona

Gakona is a small community located about6 mi west of the TAPS, adjacent to theconfluence of the Copper and Gakona rivers atMP 2 of the Tok Cutoff to the Glenn Highway(Figure D-3) (ADF&G 2001). The site of Gakonawas originally used for Ahtna Athabascansettlements. As a transportation systemdeveloped in the Copper River Valley, a non-Native presence began to be seen in Gakonaearly in the 20th century, initially in the form ofroadhouses and a post office (Northern LandUse Research, Inc. 2000a). The population inGakona was 215 in 2000 (Table D-1), althoughthis number reflects a dispersed settlementalong the Tok Cutoff (Northern Land UseResearch, Inc. 2000a). The economy of Gakonarelies largely on wages obtained from localbusinesses and seasonal tourism, supplementedby a relatively small amount of subsistence.

Gakona residents participating insubsistence obtained roughly equal amounts ofmeat from large land mammals (47.6 edible lbper capita) and fish (40.9 edible lb per capita) in1987 (Table D-12) (Fall et al. 2001; see alsoNational Park Service 1995; Simeone and Fall1996; Stratton and Georgette 1984). Despite thedominant role of a cash economy in thecommunity, nearly 86% of the householdssurveyed used fish and almost 64% used largeland mammals obtained from subsistenceactivities. Part of the traditional subsistenceharvest area for Gakona intersects a section ofthe TAPS, and another section of this areainvolves the Copper River downstream from thepipeline (Figure D-11). Other than those areas,only small areas of the Copper River are usedfor any type of fish harvest. Subsistenceconcerns identified during the 1980s includehunting and fishing bag limits (particularly oncaribou and salmon) and both potentialincreased competition for resources and habitatdestruction due to development in the area(ADF&G 2001).

APPENDIX D D-50

TABLE D-12 Subsistence Harvest Summary for Gakona in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 58 9,936 141.9 47.6 62.2 63.6 Brown bear 1 100 1.4 0.5 1.4 1.4 Caribou 35 4,609 65.8 22.1 44.9 50.6 Dall sheep 11 727 10.4 3.5 16.0 23.2 Moose 10 4,500 64.3 21.5 14.3 53.5

Small land mammal/furbearerb 625 140 2.0 0.7 46.4 46.4 Hare 93 140 2.0 0.7 26.1 26.1

Fishes and Marine InvertebratesTotal fish 8,549 8,549 122.1 40.9 69.5 85.5 Total salmon 1,195 6,074 86.8 29.1 57.9 68.1 Total non-salmon 2,476 2,476 35.4 11.9 57.9 69.5 Burbot 201 483 6.9 2.3 26.1 27.5 Char 391 539 7.7 2.6 27.5 30.4 Cod 140 140 2.0 0.7 1.4 1.4 Flounder 12 12 0.2 0.1 1.4 1.4 Grayling 725 508 7.3 2.4 50.6 57.9 Halibut 342 342 4.9 1.6 11.6 60.9 Rockfish 2 8 0.1 0.0 1.4 1.4 Trout 176 251 3.6 1.2 18.8 18.8 Whitefish 215 194 2.8 0.9 17.4 17.4Marine invertebrate 93 93 1.3 0.5 10.1 31.9 Clam 53 53 0.8 0.3 8.7 23.2 Shrimp 40 40 0.6 0.2 1.4 8.7

BirdsTotal bird and egg 790 424 6.1 2.0 52.2 52.2 Migratory bird 140 99 1.4 0.5 8.7 8.7 Duck 140 99 1.4 0.5 8.7 8.7 Upland game bird 650 325 4.6 1.6 52.2 52.2 Grouse 359 180 2.6 0.9 50.8 50.8 Ptarmigan 291 145 2.9 0.7 17.4 17.4


b Several types of small land mammals (beaver, coyote, red fox, land otter, marten, mink, muskrat,porcupine, tree squirrel, weasel, wolf, and wolverine) were reported as harvested by certain households,although 0 was reported as total harvested. Because of this inconsistency, these small land mammalswere excluded from this table.


D-51 APPENDIX D


FIGURE D-11 Subsistence Harvest Areas Associated with Gakona (Data Source:ADF&G undated)

D-53 APPENDIX D

D.3.3.10 Glennallen

Glennallen is located on the Glenn Highwaynear its intersection with the RichardsonHighway, about 3.5 mi west of the TAPS(Figure D-3) (ADCED 2001). Founded in theearly 1940s as a U.S. Army camp for troopsbuilding a road and airfield (Stratton andGeorgette 1984), the population of Glennallentotaled 554 by 2000 (Table D-1). Largelybecause of Glennallen�s location at theintersection of two major highways and itsproximity to Wrangell-St. Elias National Park,community residents have more opportunities forwage employment than most rural Alaskans.Wage labor provides most of the livelihood inGlennallen, primarily involving work forgovernment agencies (many of which have localheadquarters there) and businesses serving thehighway tourism industry (ADCED 2001).Subsistence helps to supplement wage income.

As shown in Table D-13, Glennallenresidents harvested a wide range of terrestrialmammals, fish, and birds. Although as many as71% of the households surveyed pursued certainresources, none of these resources wereharvested in large quantities. Fish and large landmammals provided the greatest amounts(54 and 43 edible lb per capita, respectively)(Fall et al. 2001; see also National Park Service1995; Simeone and Fall 1996). These lowamounts indicate the relative importance of othercomponents of the economy, primarily wagelabor. The traditional subsistence harvest areafor Glennallen intersects the TAPS for more than75 mi along the pipeline, and includes largesections of the Copper River downstream fromthe pipeline (Figure D-12). Subsistenceconcerns identified in 1987 include habitatdestruction and potentially increasedcompetition for subsistence resources due todevelopment in the area (ADF&G 2001).

APPENDIX D D-54

TABLE D-13 Subsistence Harvest Summary, Glennallen in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 106 20,053 118.0 42.7 39.3 75.3 Black bear 5 35 0.2 0.1 7.2 7.2 Caribou 68 8,840 52.0 18.8 33.1 56.8 Dall sheep 5 341 2.0 0.7 2.1 3.1 Deer 4 149 0.9 0.3 1.0 1.0 Moose 24 10,688 62.9 22.8 14.0 49.0

Sm. land mammal/furbearerb 306 366 2.2 0.8 8.4 8.4 Beaver 22 53 0.3 0.1 1.6 1.6

Coyotec 4 −d − − 1.0 1.0

Foxc 4 − − − 1.0 1.0

Hare 209 314 1.8 0.7 5.7 5.7

Martenc 51 − − − 2.6 2.6

Muskratc 12 − − − 0.6 0.6

Weaselc 6 − − − 1.6 1.6

Fishes and Marine InvertebratesTotal fish 25,287 25,287 148.8 53.9 71.2 95.9 Total salmon 3,785 19,136 112.6 40.8 59.9 94.9 Total non-salmon 6,152 6,152 36.2 13.1 42.4 62.9 Burbot 139 334 2.0 0.7 9.9 11.9

Char 299 335 2.0 0.7 14.0e 14.0e

Grayling 2,119 1,483 8.7 3.2 26.9 37.2 Halibut 1,645 1,645 9.7 3.5 3.1 22.2 Pike 53 147 0.9 0.3 2.1 2.1 Rockfish 110 441 2.6 0.9 2.1 2.1

Trout 1,108 1,575 9.3 3.4 16.0e 16.0e

Whitefish 213 192 1.1 0.4 5.7 5.7 Marine invertebrate 26 26 0.2 0.1 1.0 1.0

Clamf 26 26 0.2 0.1 1.0 1.0

BirdsTotal bird and egg 339 174 1.0 0.4 21.2 23.2 Migratory bird 40 25 0.2 0.1 3.1 4.1 Duck 40 25 0.2 0.1 3.1 4.1 Upland game bird 299 150 0.9 0.3 19.1 20.1 Grouse 180 90 0.5 0.2 18.1 19.1 Ptarmigan 119 60 0.4 0.1 5.1 6.2 Bird egg 312 174 1.0 0.4 36.6 37.6


D-55 APPENDIX D

TABLE D-13 (Cont.)


b Some not eaten.

c Not eaten.



f Unit of measure is gallon.


APPENDIX D D-56

D-57 APPENDIX D


FIGURE D-12 Subsistence Harvest Areas Associated with Glennallen (Data Source:ADF&G undated)

D-59 APPENDIX D

D.3.3.11 Gulkana

Gulkana is a small village located on theeast bank of the Gulkana River where it joins theCopper River, about 3 mi east of the TAPS(Figure D-3) (ADCED 2001). The village had itsorigins as an Ahtna Athabascan settlement, ofwhich there were several along the GulkanaRiver at various times in the past. Non-Nativesbegan to occupy the locality of present-dayGulkana in 1901, with the establishment of atrading post and telegraph station. Today thevillage is home to Natives and non-Natives. Thetotal number of residents reached 88 in 2000(Table D-1). The village economy is mixed.Although subsistence hunting, fishing, gathering,and trapping provided key resources well intothe late 1980s, year-round and seasonal wageemployment in government, construction, andother parts of the cash economy has shownsigns of growth in recent years (Northern LandUse Research, Inc. 2000a).

In terms of edible pounds harvested, fishcontributed about twice as much as large

mammals to the Gulkana subsistence economyin 1987 (Table D-14) (Fall et al. 2001; see alsoNational Park Service 1995; Simeone and Fall1996; Stratton and Georgette 1984). Despite therelatively small amounts harvested, 90% of thehouseholds surveyed fished for one species oranother; 95% of the households used fish; and70% used large land mammals. About half thehouseholds examined in 1987 hunted or trappedsmall mammals, which suggests trapping mightplay an important role as a means ofsupplementing cash income. Part of thetraditional subsistence harvest area for Gulkanaoverlaps with a section of the TAPS, particularlyalong the pipeline (Figure D-13). In addition, theharvest area for this community includes part ofthe Copper River downstream from the pipeline,although none of this portion of the river wasused for fishing. Subsistence concerns identifiedduring the 1980s included hunting and fishingbag limits (particularly on caribou and salmon)and both potential increased competition forresources and habitat destruction due todevelopment in the area (ADF&G 2001).

APPENDIX D D-60

TABLE D-14 Subsistence Harvest Summary for Gulkana in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 13 3,036 138.00 45.25 35.0 70.0 Black bear 1 55 2.5 0.8 5.0 5.0 Caribou 8 1,001 45.5 14.9 30.0 55.0 Moose 4 1,980 90.0 29.5 20.0 55.0

Small land mammal/furbearerb 308 527 24.0 7.9 50.0 55.0 Beaver 8 116 5.3 1.7 10.0 15.0

Coyote 6 −c − − 5.0 5.0

Foxd 6 − − − 5.0 5.0 Hare 81 122 5.6 1.8 30.0 35.0 Lynx 6 22 1.0 0.3 5.0 5.0

Martend 32 − − − 10.0 10.0

Minkd 11 − − − 5.0 5.0 Muskrat 132 238 10.8 3.6 10.0 15.0 Porcupine 7 30 1.4 0.5 20.0 20.0

Weaseld 8 − − − 5.0 5.0

Wolfd 6 − − − 5.0 5.0

Wolverined 6 − − − 5.0 5.0

FishesTotal fish 6,406 6,406 291.2 95.5 90.0 95.0 Total salmon 1,296 5,777 262.6 86.1 60.0 85.0 Total non-salmon 629 629 28.6 9.4 70.0 70.0 Burbot 67 161 7.3 2.4 15.0 2.0

Char 12 15 0.7 0.2 5.0e 5.0e

Grayling 209 146 6.7 2.2 65.0 65.0 Greenling 4 4 0.2 0.1 5.0 5.0 Halibut 55 55 2.5 0.8 5.0 5.0 Sucker 110 77 3.5 1.2 5.0 5.0 Trout 9 12 0.6 0.2 10.0 10.0 Whitefish 176 158 7.2 2.4 15.0 25.0

BirdsTotal bird and egg 117 92 4.2 1.4 20.0 30.0 Migratory bird 58 63 2.9 0.9 15.0 25.0 Duck 36 36 1.7 0.5 10.0 20.0 Goose 22 28 1.2 0.4 5.0 5.0 Upland game bird 58 29 1.3 0.4 20.0 20.0 Grouse 33 17 0.8 0.3 20.0 20.0 Ptarmigan 25 13 0.6 0.2 10.0 10.0


D-61 APPENDIX D

TABLE D-14 (Cont.)


b Some not eaten.

c �−� = 0 or a number that rounds to 0.

d Not eaten.



APPENDIX D D-62

D-63 APPENDIX D


FIGURE D-13 Subsistence Harvest Areas Associated with Gulkana (Data Source:ADF&G undated)

D-65 APPENDIX D

D.3.3.12 Hughes

Hughes lies on a tall bluff on the east bankof the Koyukuk River, some 105 mi west of theTAPS (Figure D-3) (ADCED 2001). Located inan area that included Athabascans, Kobuk,Selawik, and Nunamiut, the community ofHughes was founded formally in 1910 as ariverboat landing and supply port for the IndianRiver gold fields. Its population varied during the20th century, as gold fields and variouseconomic activities came and went. The mostrecent decennial census in 2000 recorded 78people in Hughes (Table D-1). Due in large partto Hughes� geographic isolation, the majoreconomic activity there today is subsistence.

Residents of Hughes harvested a broadrange of land mammals, birds, and fish in 1982,the reference year for the community(Table D-15) (Marcotte and Haynes 1984; seealso Brannian and Gnath 1988). Salmon by farcontributed the greatest amount of edible pounds

harvested, providing more than 1,234 lb percapita for households surveyed. The number ofhouseholds participating in harvesting washigher for large and small land mammals andbirds (and certain other types of fish) than forsalmon, although the harvest totals of thosespecies were much lower than those of salmon.Small land mammal and furbearer harvests werehigh (in terms of numbers harvested, althoughmany were not eaten), indicating that trappingplayed an important role in providingsupplemental cash income. The traditionalsubsistence harvest area for Hughes does notintersect the TAPS, but it does include part of theKoyukuk River downstream from the pipeline(used primarily for moose rather than fish)(Figure D-14). Subsistence concerns identifiedduring the early1980s included increasedcompetition for subsistence resources due toimproved access, sporadic caribou migration (noreason proposed), and low moose populations(in 1987, again with no reasons proposed)(ADF&G 2001).

APPENDIX D D-66

TABLE D-15 Subsistence Harvest Summary for Hughes in 1982a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 56 20,113 914.2 211.8 78.9b NAc

Black bear 17 1,007 45.8 10.6 52.6 NA

Moose 38 19,105 868.4 201.2 78.9 NA

Small land mammal/furbearerd 1,121 1,551 70.5 16.3 89.5b NA

Beaver 113 998 45.4 10.5 63.2 NA

Hare 368 552 25.1 5.8 5.81 NA

Land ottere 5 −f − − 10.5 NA

Lynxe 63 − − − 52.6 NA

Martene 470 − − − 84.2 NA

Muskrate 47 − − − 42.1 NA

Wolverinee 7 − − − 21.0 NA

FishesTotal fish 21,745 117,180 5,326.4 1,234.1 84.2b NA

Total salmon 16,939 110,356 5,016.1 1,162.3 68.4b NA

Total non-salmon 4,806 6,825 310.2 71.9 84.2b NA

Burbot 69 167 7.6 1.6 10.5 NA

Grayling 1,593 1,115 50.7 11.7 84.2 NA

Pike 244 684 31.1 7.2 52.6 NA

Sheefish 371 2,594 117.9 27.3 78.9 NA

Sucker 57 39 1.8 0.4 31.6 NA

Whitefish 2,472 2,226 101.6 23.4 − NA

BirdsTotal bird and egg 1,079 2314 105.2 24.4 78.9b NA

Migratory bird 849 2198 99.9 23.2 78.9b NA

Duck 585 878 39.9 9.3 78.9 NA

Goose 264 1320 60. 13.9 73.7 NA

Upland game bird 230 116 5.3 1.2 68.4b NA

Grouse 139 70 3.2 0.7 68.4 NA

Ptarmigan 91 46 2.1 0.5 52.6 NA


b Data not recorded; value reported is the maximum of those recorded for subcategories.

c NA = data not available.

d Some not eaten.

e Not eaten.

f �−� = 0 or a number that rounds to 0.


D-67 APPENDIX D


FIGURE D-14 Subsistence Harvest Areas Associated with Hughes (Data Source:ADF&G undated)

D-69 APPENDIX D

D.3.3.13 Kenny Lake

Kenny Lake is a small community locatedabout 7 mi east of the TAPS in the centralCopper River Basin (Figure D-3) (ADCED 2001).Although in the past, Ahtna Athabascans lived inthe vicinity of Kenny Lake, the moderncommunity consists primarily of people whohomesteaded agricultural land there in the 1950sand 1960s. The total population of Kenny Lake in2000 was 410, having declined from 507 only adecade earlier (Table D-1), and the inhabitedarea comprises a 16-mi length of the EdgertonHighway (Northern Land Use Research, Inc.2000a). The economy of Kenny Lake isdominated by wage labor, with the majority ofemployment being in commercial agriculture, butcertain small businesses provide jobs as well.Subsistence activities supplement wage labor.

The relatively small amounts of landmammals, fish, and birds that were harvested in

1987 suggest the secondary role thatsubsistence plays in the overall economy(Table D-16) (Fall et al. 2001; National ParkService 1995). The largest contribution tosubsistence was from fishing, in totalcontributing 83 edible lb per capita; salmonalone contributed more than 67 lb per person.Nearly 90% of the surveyed households fished,and 98% consumed fish. Large game provided47 edible lb per person in households surveyed,with moose providing nearly 23 lb and caribouanother 17 lb. A large section of the subsistenceharvest area for Kenny Lake overlaps with theTAPS (Figure D-15). In addition, the harvestarea for this community includes part of theCopper River downstream from the pipeline,including portions of the river used for salmonand other fish as well as waterfowl. Subsistenceconcerns identified during the late 1980sincluded both potential increased competition forresources and possible habitat destruction dueto development in the area (ADF&G 2001).

APPENDIX D D-70

TABLE D-16 Subsistence Harvest Summary for Kenny Lake in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 81 15,257 161.9 47.0 61.1 73.0

Black bear 10 1,749 18.8 5.5 10.6 10.6

Caribou 43 5.578 60.0 17.4 37.4 41.1

Deer 12 517 5.6 1.6 10.6 10.6

Moose 16 7,216 77.6 22.5 17.2 37.4

Small land mammal/furbearerb 337 196 2.1 0.6 27.8 27.8

Beaverc 2 −d − − 2.4 2.4

Foxc 8 − − − 8.2 8.2

Hare 131 196 2.1 0.6 19.3 19.3

Martenc 0 − − − 7.5 7.5

Muskratc 0 − − − − 2.4

Tree squirrelc 27 − − − 2.4 2.4

Weaselc 8 − − − 8.2 8.2

Wolfc 0 − − − 2.6 2.6

Wolverinec 0 − − − 2.6 2.6

FishesTotal fish 26,609 26,609 286.1 83.0 89.4 97.6 Total salmon 4,315 21,616 232.4 67.4 56.6 64.8 Total non-salmon 4,993 4,993 53.7 15.6 83.4 88.3 Burbot 85 204 2.2 0.6 11.9 11.9 Grayling 996 697 7.5 2.2 72.2 72.2 Trout 231 324 3.5 1.0 23.1 23.1 Whitefish 114 102 1.1 0.3 2.4 2.4

BirdsTotal bird and egg 1,059 548 5.9 1.7 44.2 44.2 Migratory bird 91 64 0.7 0.2 4.9 4.9 Ducks 91 64 0.7 0.2 4.9 4.9 Upland game bird 968 484 5.2 1.5 44.2 44.2 Grouse 418 209 2.3 0.7 34.7 34.7 Ptarmigan 550 275 3.0 0.9 19.4 19.4


b Some not eaten.

c Not eaten.



D-71 APPENDIX D


FIGURE D-15 Subsistence Harvest Areas Associated with Kenny Lake (DataSource: ADF&G undated)

D-73 APPENDIX D

D.3.3.14 Manley Hot Springs

Manley Hot Springs is a small,unincorporated community located roughly 65 miwest of the TAPS (Figure D-3). Lying about 5 minorth of the Tanana River at the end of ElliottHighway, Manley Hot Springs began as a singlehomestead, supply point for miners, and U.S.Army telegraph station in the early 1900s(ADCED 2001). The hot springs for which thevillage eventually was named provided the basisfor a resort which, mixed with mining and smallamounts of government employment, provided abasis for the community�s early economy. Wage-based economy eventually faltered, and thepopulation of Manley Hot Springs declined. Thetotal number of inhabitants in 2000 was recordedat 78 (Table D-1). The current economy ofManley Hot Springs involves employment indiverse areas (such as small businesses, thegovernment, and commercial fishing) andinvolvement in subsistence.

Gardening, hunting, and fishing play animportant role in providing food for residents ofManley Hot Springs, with salmon and moosebeing particularly important (Betts 1997;Brannian and Gnath 1988). Specific data onharvest levels, participation rates, and specificsubsistence concerns were not available fromthe ADF&G. However, subsistence datacompiled recently for an environmentalassessment of road construction in the Manleyarea indicate that a broad range of largemammals, small mammals, fish, and birds areexploited (Table D-17) (Betts 1997). Manley HotSprings residents harvested more than30,130 salmon in 1995 (more than 386 perperson based on 2000 population levels). Theresidents also harvested 843 whitefish per yearand an average of 10.8 moose per year between1990 and 1995. The subsistence harvest areadoes not intersect the TAPS, although it doesinclude sections of the Yukon and TananaRivers downstream from the pipeline(Figure D-16). Subsistence concerns wereprimarily related to competition from nonlocalhunters for several species (moose, bear, andgrouse) that also are important for subsistence(Betts 1997).

TABLE D-17 Subsistence ResourcesHarvested by Residents in the ManleyHot Springs and Eureka Area in 1996a

Subsistence ResourceAmount

Harvested

Terrestrial MammalsLarge land mammal NAa

Black bear NA Caribou NA Moose NASmall land mammal/furbearer NA Beaver NA Fox NA Hare NA Land otter NA Lynx NA Marten NA Mink NA Muskrat NA Porcupine NA Squirrel NA Weasel NA Wolf NA Wolverine NA

FishesTotal fish NA Total salmon NA Total non-salmon NA Burbot NA Char NA Grayling NA Greenling (Lingcod) NA Pike NA Sheefish NA Whitefish NA

BirdsTotal bird and egg NA Migratory bird NA Crane NA Duck NA Goose NA Upland game bird NA Grouse NA Ptarmigan NA

a NA = data not available.

Source (for species harvested): Northern Land UseResearch, Inc., and Vanguard Research (1997).

APPENDIX D D-74

D-75 APPENDIX D


FIGURE D-16 Subsistence Harvest Areas Associated with Manley Hot Springs (DataSource: Betts 1997)

D-77 APPENDIX D

D.3.3.15 Minto

Minto lies on the western bank of theTolovana River, roughly 47 mi south of the TAPS(Figure D-3) (ADCED 2001). The precursor ofMinto, now called Old Minto, was founded on theTanana River by members of the Minto band ofAthabascans in 1915 (Olson 1981). Gradually,that village grew as a Bureau of Indian Affairsschool (founded in 1937) and other amenitiesattracted members of other bands. The originalcommunity of Minto was relocated in 1969 aftera series of floods (ADCED 2001). In 2000, thepopulation of Minto was 258 people (Table D-1).The village economy of Minto is mixed, althoughsubsistence plays a particularly important role.Wage employment is predominantly seasonal,although some jobs with the local school,medical clinic, and village council are year-round.

The most important subsistence resourcerecorded by the ADF&G in 1984 was fish, whichyielded more than 860 lb per capita for thehouseholds surveyed; of this total, salmoncontributed about 687 lb per capita (Table D-18)

(Andrews 1988). Many Minto residents wereinvolved in subsistence activities, with nearly allhouseholds fishing (often traveling to fish campduring the summer). Large land mammalsaccounted for nearly 91 edible lb per capita, withthe majority of this being provided by moose. Awide range of small game hunted or trappedhelped to provide both meat and (moreimportantly) furs to sell for cash. Finally, Mintoresidents also harvested a large quantity ofbirds, many coming from Minto Flatsimmediately to the southeast of the village. Partof the subsistence harvest area for Mintointersects the TAPS, while a larger sectionincludes the Tanana River and associated valleydownstream from the pipeline (Figure D-17).Subsistence concerns identified in 1984 includedhabitat destruction due to mining; excessiveconstraints of certain hunting regulations;competition for moose, waterfowl, furbearers,and pike (with low populations of moose andpike) from nonlocal hunters and fishermen; anddisruption of fish and game by airboats used bynonlocal hunters and fishermen (ADF&G 2001;Betts 1997).

APPENDIX D D-78

TABLE D-18 Subsistence Harvest Summary for Minto in 1984a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 36 16,987 353.9 90.5 86.7 NAb

Black bear 16 2,800 58.3 14.9 20.0 NA

Moose 20 14,187 295.6 75.6 40.0 NA

Small land mammal/furbearerc 1,502 5,861 122.1 31.2 84.4 NA

Beaver 147 4,122 85.9 22.0 36.0 NA

Foxd 20 −e − − 22.0 NA

Hare 389 1,090 22.7 5.8 60.0 NA

Land otterd 16 − − − 11.0 NA

Lynxd 4 − − − 7.0 NA

Martend 299 − − − 47.0 NA

Minkd 26 − − − 13.0 NA

Muskrat 569 398 8.3 2.1 40.0 NA

Porcupine 13 251 5.2 1.3 18.0 NA

Weaseld 18 − − − 9.0 NA

Wolfd 1 − − − 2.0 NA

FishesTotal fish 36,218 161,510 3364.8 860.2 88.9 NA Total salmon 24,372 128,891 2685.22 686.6 77.8 NA Total non-salmon 11,846 32,619 679.6 173.8 73.3 NA Burbot 151 515 10.7 2.7 31.0 NA Pike 3,203 14,414 300.3 76.8 60.0 NA Sheefish 381 2,285 47.6 12.2 27.0 NA Sucker 1,634 2,451 51.1 13.1 40.0 40.0 Whitefish 6,477 12,954 269.9 69.0 69.0 69.0

BirdsTotal bird and egg 2,428 4,832 100.7 25.8 84.4 NA Migratory bird 1,846 4,541 94.6 24.2 82.2 NA Duck 1,339 2,008 41.8 10.7 82.0 NA Goose 507 2,533 52.8 13.5 64.0 NA Upland game bird 582 291 6.1 1.6 73.0 NA


b �NA� = data not available.

c Some not eaten.

d Not eaten.

e �−� = 0 or a number that rounds to 0.


D-79 APPENDIX D


FIGURE D-17 Subsistence Harvest Areas Associated with Minto (Data Source:Andrews 1988)

D-81 APPENDIX D

D.3.3.16 Nanwalek

Nanwalek lies at the southern tip of theKenai Peninsula, about 252 mi west of the TAPS(Figure D-3) (ADCED 2001). Originally the siteof a Russian trading post called Alexandrovsk,Nanwalek is primarily an Alutiiq village today. In2000, the decennial census recorded apopulation of 177 (see Table D-1). Althoughsome wage employment is available, mainlythrough seasonal work at the Port GrahamCannery and in commercial fishing, subsistenceis extremely important to the village economy.

One of the most noteworthy characteristicsof subsistence in Nanwalek is the broad range ofmarine and terrestrial resources harvested byvillage residents (Table D-19). A marineadaptation is evident in harvest patterns, withfish as a whole providing nearly 200 edible lb percapita. All households surveyed participated in

subsistence fishing and used fish for food.Marine mammals (primarily seals) also provide asource of subsistence for Nanwalek residents,as do large land mammals and marineinvertebrates. Nanwalek subsistence harvestareas for all species pursued are well west of theTAPS (Figure D-18) (see also Ganley 2001;Ganley and Wheeler 2000). Subsistenceconcerns identified during the late 1980s andearly1990s included persisting contaminationdue to the Exxon Valdez oil spill; low populationsof seals, sea lions, some waterfowl, sockeyesalmon, and a number of marine invertebrates;and competition with nonresidents for blackbear, moose, goats, salmon, and halibut(ADF&G 2001). Data collected after the ExxonValdez spill indicate that declines in subsistenceharvests persisted for several years following the1989 spill (Fall 1999).

APPENDIX D D-82

TABLE D-19 Subsistence Harvest Summary for Nanwalek in 1997a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Marine MammalsMarine mammalb 69 4,020 105.8 24.0 34.5 89.7

Sea otterc 10 −d − − 6.9 10.3

Seal 53 2,972 78.2 17.7 34.5 89.7

Steller sea lion 5 1,048 27.6 6.3 6.9 27.6


Black bear 10 608 16.0 3.6 13.8 65.5

Moose 3 1,415 37.2 8.4 6.9 37.9


Land otterc 3 − − − 3.4 3.4

Porcupine 1 10 0.3 0.1 3.4 3.4

Squirrelc 4 − − − 3.4 3.4

Weaselc 7 − − − 6.9 6.9

Fishes and Marine InvertebratesTotal fish 33,458 33,458 880.5 199.5 100.0 100.0

Total salmon 7,011 26,474 696.7 157.8 100.0 100.0

Total non-salmon 6,984 6,984 183.8 41.6 89.7 93.1

Bass 31 31 0.8 0.2 10.3 13.8

Char 829 1,161 30.6 6.9 65.5 69.0

Cod 719 1,085 28.6 6.5 48.3 69.0

Flounder 3 8 0.2 0.1 3.4 3.4

Greenling 63 94 2.5 0.6 31.0 34.5

Halibut 3,501 3,501 92.1 20.9 55.2 93.1

Herringe 8 46 1.2 0.3 10.3 48.3

Herring roee 1 5 0.1 - 3.4 3.4

Rockfish 189 316 8.3 1.9 17.2 24.1

Sablefish 75 232 6.1 1.4 10.3 13.8

Sculpin 38 19 0.5 0.1 10.3 13.8

Shark 1 12 0.3 0.1 3.4 3.4

Skate 1 7 0.2 - 3.4 3.4

Smelte 12 38 1.0 0.2 6.9 51.7

Trout 307 430 11.3 2.6 37.9 48.3


Chitone 221 874 23.0 5.2 58.6 75.9

Clame 59 177 4.7 1.1 17.2 34.5

Limpete 4 6 0.2 - 10.3 10.3

Mussele 34 51 1.3 0.3 34.5 34.5

Octopus 84 335 8.8 2.0 58.6 75.9

Snaile 44 66 1.7 0.4 48.3 58.6

D-83 APPENDIX D

TABLE D-19 (Cont.)


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Birds and Bird EggsTotal bird and egg 1,106 603 15.9 3.6 44.8 72.4

Migratory bird 430 384 10.1 2.3 34.5 41.4

Crane 3 22 0.6 0.1 3.4 3.4

Ducks 390 331 8.7 2.0 31.0 34.5

Seabird and loon 37 31 0.8 0.2 13.8 17.2

Upland game bird 39 28 0.7 0.2 17.2 17.2

Grouse 39 28 0.7 0.2 17.2 17.2

Bird egg 637 191 5.0 1.1 31.0 62.1


b Some not eaten.

c Not eaten.



Source: ADF&G 2001 (sums corrected as necessary).

APPENDIX D D-84

D-85 APPENDIX D


FIGURE D-18 Subsistence Harvest Areas Associated with Nanwalek (Data Source:ADF&G undated)

D-87 APPENDIX D

D.3.3.17 Nuiqsut

Nuiqsut is an incorporated community lyingon the western bank of the Nechelik Channel ofthe Coleville River Delta, about 57 mi west of theTAPS (Figure D-3) (ADCED 2001). Originally thelocation of a Native Village called Itquilippaa, theold community was abandoned in the 1940s andresettled in 1973 by several Tareumiut familiesfrom Barrow (Impact Assessment, Inc. 1990).The population of Nuiqsut was 433 in 2000(Table D-1). Although some wage employment isavailable in nearby oil fields and with NorthSlope Borough and state governments,subsistence remains extremely important to theNuiqsut economy (North Slope Borough 1999).

Marine mammals (notably whales), largeland mammals (especially caribou), and fish(notably whitefish) each contributed more than230 lb of subsistence resource per capita tohouseholds surveyed in Nuiqsut in 1993 (TableD-20) (Impact Assessment, Inc. 1990; Fall andUtermohle 1995). Hunting large land mammalsand fishing involved 74 and 81%, respectively, ofthe Nuiqsut households studied that year. Morethan 98% of those households used large landmammals, 100% used fish, and nearly 97% usedmarine mammals for subsistence. Birds, birdeggs, and small land mammals completed thesubsistence resources for Nuiqsut in 1993, butthe amount harvested was negligible in

comparison to the three categories noted above(although more than 95% of householdssurveyed used birds and bird eggs). Althoughdetailed data are lacking, available evidenceindicates that harvest patterns, in the sense ofspecies mix and level of importance, would besimilar over time (Libby et al. 1979; North SlopeBorough Planning Commission and Commissionon History and Culture 1979; see also ADF&G1986). Subsistence data from 1994−1995, theyear following the representative year presentedin Table D-20, indicate that the breadth insubsistence species and in their emphasis wassimilar then, with caribou being particularlyimportant (Brower and Opie 1997). The easternedge of the subsistence harvest area used byNuiqsut residents for caribou intersects theTAPS (Figure D-19).

Subsistence concerns identified during 1985and 1993 included habitat destruction due toincreasing oil and gas development and growingcompetition for subsistence resources due tolarger populations and improved access tononlocal hunters (ADF&G 2001). Problemsidentified in 1995−1996 included aircraft thatwere scaring caribou; musk oxen that wereaffecting caribou movements; an absence ofcaribou; a lack of access to equipment (such asa working snow machine) to enable hunting; andthe possibility that modern activities might havebeen poisoning game (Brower and Opie 1997).

APPENDIX D D-88

TABLE D-20 Subsistence Harvest Summary for Nuiqsut in 1993a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Marine MammalsTotal marine mammal 113 85,216 936.4 236.0 37.1 96.8 Bowhead whale 3 76,906 845.1 213.0 4.8 96.8

Polar bearb 1 0 0.0 0.0 1.6 51.6 Seal 109 8,310 91.3 23.0 35.5 71.0

Terrestrial MammalLarge land mammal 691 87,306 959.4 241.8 74.2 98.4 Brown bear 10 734 8.1 2.0 8.1 32.3 Caribou 672 82,169 903.0 227.6 74.2 98.4 Moose 9 4,403 48.4 12.2 9.7 69.4


Arctic foxb 203 −d − − 12.9 16.1

Parka squirrel 336 84 0.9 0.2 16.1 17.7

Red foxb 63 − − − 22.6e 27.4e

Weaselb 10 − − − 3.2 3.2

Wolfb 31 − − − 11.3 21.0

Wolverineb 19 − − − 16.1 22.6

FishesTotal fish 71,897 90,490 994.4 250.6 80.6 100.0 Total salmon 272 1,009 11.1 2.8 35.5 71.0 Total non-salmon 71,626 89,481 983.3 247.8 79.0 96.8 Burbot 1,416 5,949 65.4 16.5 56.5 79.0 Char 618 1,748 19.2 4.8 32.3 50.0 Cod 62 7 0.1 - 6.5 12.9 Grayling 4,515 4,063 44.7 11.3 64.5 79.0 Smelt 304 42 0.5 0.1 12.9 33.9 Whitefish 64,711 77,671 853.5 215.1 74.2 95.2

BirdsTotal bird and egg 3,558 4,325 47.5 12.0 75.8 95.3 Migratory bird 2,238 3,540 38.9 9.8 72.6 87.1 Duck 772 1,152 12.7 3.2 38.7 62.9 Goose 1,459 2,314 25.4 6.4 72.6 87.1 Swan 7 73 0.8 0.2 8.1 11.3 Upland game bird 973 681 7.5 1.9 45.2 59.7 Ptarmigan 973 681 7.5 1.9 45.2 59.7 Bird egg 346 104 1.1 0.3 19.4 40.3


D-89 APPENDIX D

TABLE D-20 (Cont.)


b Not eaten.

c Some not eaten.

d �−� = 0 or a number that rounds to 0 .



APPENDIX D D-90

D-91 APPENDIX D


FIGURE D-19 Subsistence Harvest Areas Associated with Nuiqsut (Data Source:Bieganski 2001)

D-93 APPENDIX D

D.3.3.18 Paxson

Paxson is a small rural community lyingabout 4 mi west of the TAPS in the Copper RiverBasin, at the intersection of the Richardson andDenali Highways (Figure D-3) (ADCED 2001).Located in an area of considerable priorAthabascan occupation, Paxson was firstoccupied during construction of the Valdez-Fairbanks Trail (later the Richardson Highway)in the early 20th century. An initial roadhousewas augmented by a U.S. Army telegraphstation, but the community never evolvedbeyond a small settlement of a few dozenpeople. In 2000, Paxon�s total population was 43(see Table D-1). The community has a mixedeconomy, although wage labor is the dominantcomponent as residents take advantage of theirproximity to two major highways to work forsmall local businesses that provide services totravelers or for the government (primarily inhighway maintenance). Subsistence serves asan important means of supplementing this ruralcash economy.

Subsistence activities yielded relativelysmall harvests, which reflects in part the fact thatcash is available to residents of Paxson. Largeland mammals provided the greatest amount ofedible pounds harvested: about 139 lb per capitain the reference year of 1987 (Table D-21) (Fallet al. 2001; see also National Park Service1995). Fish provided slightly fewer poundsharvested, at 107 edible lb per capita; fish otherthan salmon provided more edible poundsharvested (about 63) than did salmon (about45 lb). Hunting and trapping small mammalsprovided a relatively small amount of edibleresources. Most animals were harvested for fur,presumably to sell for additional cash. At leasthalf the households surveyed participated in theharvest of large and small mammals, fish, birds,and eggs, with up to 86% of those householdsusing the same resources. Part of the Paxsonsubsistence harvest area intersects the TAPS,including a section of the Gulkana Riverdownstream from the pipeline used for salmonfishing (Figure D-20). Subsistence concernsidentified during the late 1980s included bothpotential increased competition for resourcesand possible habitat destruction due todevelopment in the area (ADF&G 2001).

APPENDIX D D-94

TABLE D-21 Subsistence Harvest Summary for Paxson in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing


Bison 1 546 32.1 14.1 7.1 21.4

Caribou 10 1,263 74.3 32.5 42.9 57.1

Dall sheep 5 316 18.6 8.1 28.6 28.6

Moose 7 3,279 192.9 84.4 42.9 64.3


Beaver 94 838 49.3 21.6 35.7 35.7

Coyotec 4 −d − − 14.3 14.3

Foxc 114 − − − 28.6 28.6

Hare 38 56 3.3 1.4 28.6 28.6

Land otterc 10 − − − 21.4 21.4

Martenc 67 − − − 35.7 35.7

Muskratc 40 − − − 14.3 14.3

Weaselc 9 − − − 14.3 14.3

Wolfc 2 − − − 7.1 7.1

FishesTotal fish 4,163 4,163 244.9 107.1 78.6 85.7 Total salmon 317 1,730 101.8 44.5 42.9 64.3 Total non-salmon 2,432 2,432 143.1 62.6 78.6 78.6 Burbot 83 198 11.7 5.1 42.9 50.0 Char 186 318 18.7 8.2 64.3e 64.3e

Grayling 182 128 7.5 3.3 78.6 78.6 Halibut 80 80 4.7 2.1 14.3 28.6 Pike 18 51 3.0 1.3 7.1 7.1 Sucker 35 86 5.1 2.2 14.3 14.3 Trout 35 73 4.3 1.9 28.6e 28.6e

Whitefish 1,665 1,498 88.1 38.6 28.6 28.6

BirdsTotal bird and egg 778 583 31.3 15.0 71.4 71.4 Migratory bird 425 407 23.9 10.5 42.9 42.9 Duck 396 262 15.4 6.7 42.9 42.9 Goose 7 13 0.8 0.3 14.3 14.3 Upland game bird 353 177 10.4 4.6 71.4 71.4 Grouse 152 76 4.5 2.0 50.0 50.0 Ptarmigan 202 101 5.9 2.6 64.3 64.3


D-95 APPENDIX D

TABLE D-21 (Cont.)


b Some not eaten.

c Not eaten.




APPENDIX D D-96

D-97 APPENDIX D


FIGURE D-20 Subsistence Harvest Areas Associated with Paxson (Data Source:ADF&G undated)

D-99 APPENDIX D

D.3.3.19 Port Graham

Port Graham is a small fishing communitylocated at the southern end of the KenaiPeninsula, about 223 mi southwest of the ValdezMarine Terminal on the shore of Port Graham(Figure D-3) (ADCED 2001). Originally settled byRussians in the 19th century, Port Graham wasalso the location of a failed coal mine beforeactivities related to commercial fishing began inthe early 1900s. A fish cannery, originallyestablished in 1911 and rebuilt in the late 1900s,has traditionally dominated the village economy.In 2000, Port Graham contained 171 people (seeTable D-1). The economy of Port Graham ismixed (Stanek 1985). Wage employment isavailable in the nearby cannery and hatchery,and 15 residents held commercial fishinglicenses in 2000. Subsistence plays an importantrole in supplementing Port Graham�s casheconomy.

Residents of Port Graham harvested a broadrange of resources, especially marine resources.In 1997, fish provided nearly 220 edible lb percapita (Table D-22). Marine invertebrates andmarine mammals, in turn, contributed 13 and9 edible lb per capita, with terrestrial mammalsand birds completing the village subsistencesources. Almost the entire communityparticipated in subsistence fishing, and allhouseholds used fish. Large proportions of thecommunity also used marine invertebrates andmarine mammals, although only the former wereharvested by large numbers of households.Subsistence concerns identified during the late1980s and early1990s included persistingproblems due to the Exxon Valdez oil spill;habitat destruction from logging; low populationsof seals, sea lions, some waterfowl, sockeyesalmon, and a number of marine invertebrates;and competition with nonresidents for blackbear, moose, goats, salmon, and halibut(ADF&G 2001). Studies following the ExxonValdez spill indicate that subsistence declinepersisted for several years following the 1989spill (Fall 1999).

APPENDIX D D-100

TABLE D-22 Subsistence Harvest Summary for Port Graham in 1997a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Marine MammalsMarine mammal 46 1,443 22.9 9.3 27.3 81.8

Sea otter 20 −b − − 11.4 15.9

Seal 26 1,443 22.9 9.3 20.5 77.3

Terrestrial MammalsLarge land mammal 3 166 2.6 1.1 4.5 43.2

Black bear 3 166 2.6 1.1 4.5 22.7


Porcupine 7 57 0.9 0.4 6.8 6.8

Weaseld 3 − − − 2.3 2.3

Fishes and Marine InvertebratesTotal fish 34,292 34,292 544.3 219.7 90.9 100

Total salmon 4,825 22,503 357.2 144.2 86.4 100

Total non-salmon 11,789 11,789 187.1 75.5 63.6 93.2

Bass 36 36 0.6 0.2 4.5 9.1

Char 339 475 7.5 3.0 20.5 27.3

Cod 686 674 10.7 4.3 13.6 40.9

Flounder 100 301 4.8 1.9 18.2 29.5

Greenling 62 96 1.5 0.6 6.8 11.4

Halibut 8,286 8,286 131.5 53.1 56.8 84.1

Herringe 217 1,302 20.7 8.3 18.2 61.4

Herring roee 7 60 1.0 0.4 4.5 31.8

Rockfish 153 336 5.3 2.2 15.9 22.7

Sablefish 46 142 2.3 0.9 6.8 18.2

Sculpin 7 4 0.1 − 2.3 2.3

Shark 1 13 0.2 0.1 2.3 4.5

Smelte 7 23 0.4 0.2 2.3 36.4

Steelhead 13 18 0.3 0.1 9.1 13.6

Trout 30 42 0.7 0.3 11.4 18.2


Chitone 238 1,240 19.7 8.0 68.2 84.1

Clame 39 118 1.9 0.8 9.1 25.0

Cocklee 2 6 0.1 − 4.5 6.8

Crabe 6 4 0.1 − 2.3 13.6

Mussele 3 4 0.1 − 2.3 4.5

Octopus 146 584 9.3 3.7 38.6 68.2

Sea urchine 1 − − − 2.3 4.5

Snail 23 34 0.5 0.2 22.7 29.5

Whelk 1 2 − − 2.3 4.5

D-101 APPENDIX D

TABLE D-22 (Cont.)


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

BirdsTotal bird and egg 223 192 3.1 1.2 25.0 31.8 Migratory bird 203 180 2.9 1.2 20.5 22.7 Duck 203 172 2.7 1.1 20.5 22.7 Seabird and loon 3 9 0.1 0.1 2.3 2.3 Upland game bird 17 12 0.2 0.1 11.4 13.6 Grouse 17 12 0.2 − 11.4 13.6



c Some not eaten.

d Not eaten.



APPENDIX D D-102

D.3.3.20 Rampart

The village of Rampart lies on the southbank of the Yukon River, about 75 mi upstreamfrom its intersection with the Tanana River androughly 33 mi south-southwest of the TAPS(Figure D-3) (ADCED 2001). Established in 1897as a supply point on the Yukon River for nearbygold mining operations, the population ofRampart may have reached 10,000 in the firstyears of the 20th century (Betts 1997). Strikeselsewhere depleted the Rampart population justas quickly, and by 1903, only a small AlaskaNative community remained amidst theabandoned buildings of a once-thriving frontiersettlement. Population varied throughout most ofthe 20th century but remained relatively small. In2000, only 45 people resided in Rampart;closure of the school in 1999−2000 wasconsidered likely a to trigger further decline inpopulation (Table D-1). Subsistence is the maineconomic activity in this geographically isolated

community, supplemented by a small amount oflargely seasonal wage labor (including a smallamount of commercial fishing).

Data on subsistence harvests available fromADF&G are less complete for Rampart than theyusually are for rural communities. The availabledata indicate that fishing (mainly salmon andwhitefish) and hunting (primarily large game,such as caribou and moose) provided most ofthe meat for the community in 1993 (Table D-23;Brannian and Gnath 1988). Lesser amounts ofbirds and small game, the latter used mainly forthe furs they provide, completed the subsistenceharvest for Rampart. The traditional subsistenceharvest area for Rampart intersects the TAPS intwo locations and includes more than 100 mi ofthe Yukon River downstream from the pipeline(Figure D-21). Subsistence concerns includedpredation of game and competition from nonlocalhunters and commercial fishing (Betts 1997).

D-103 APPENDIX D

TABLE D-23 Subsistence Harvest Summary for Rampart in 1993a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 7 2,110 NAb NA NA NA

Black bear 1 100 NA NA NA NA

Caribou 3 390 NA NA NA NA

Moose 3 1,620 NA NA NA NA

Small land mammal/furbearerc 30 19 NA NA NA NA

Beaver 1 9 NA NA NA NA

Foxd 1 −e NA NA NA NA

Hare 3 6 NA NA NA NA

Lynxd 1 − NA NA NA NA

Martend 24 − NA NA NA NA

FishesTotal fish 5,044 26,495 NA NA NA NA Total salmon 2,766 22,512 NA NA NA NA Total non-salmon 2,278 3,684 NA NA NA NA Burbot 4 10 NA NA NA NA Grayling 143 100 NA NA NA NA Sheefish 47 258 NA NA NA NA Whitefish 2,084 3,616 NA NA NA NA

BirdsTotal bird and egg 60 42 NA NA NA NA Upland game bird 60 42 NA NA NA NA Grouse 57 40 NA NA NA NA Ptarmigan 3 2 NA NA NA NA

a Number of households in sample, and number of households in community, were not recorded.

b �NA� = data not available.

c Some not eaten.

d Not eaten.



APPENDIX D D-104

D-105 APPENDIX D


FIGURE D-21 Subsistence Harvest Areas Associated with Rampart (Data Source:Betts 1997)

D-107 APPENDIX D

D.3.3.21 Stevens Village

Stevens Village is located on the north bankof the Yukon River, about 17 mi upstream fromwhere it crosses the Dalton Highway and 20 minorth of the TAPS (Figure D-3) (ADCED 2001).The community was founded in about 1900 bythree Athabascan brothers and named after oneof them (Old Steven) when he was elected chiefin 1902 (Sumida 1988). Although StevensVillage residents provided some services topeople involved with the gold rush and receivedcertain modern amenities (e.g., a trading post inthe early 1900s, a school in 1907, and a postoffice in 1936), the population apparently neverfluctuated dramatically as did the populations ofother nearby communities. In 1987, thedecennial census recorded 87 people in StevensVillage (Table D-1). Most of the economicactivity in Stevens Village revolves aroundsubsistence, supplemented by a small amount oflargely seasonal wage labor.

Residents of Stevens Village rely on a broadrange of subsistence resources (Table D-24)(Sumida 1988). In 1984, the reference year forthis village, fishing provided more than1,023 edible lb per capita, with the vast majoritycoming from salmon (Brannian and Gnath 1988).Large land mammals provided much less ediblemeat per person surveyed, with the majoritycoming from moose. Stevens Village residentsharvested a range of small land mammals,primarily for fur (although some furbearers, suchas muskrat, also were eaten). Birds yieldedabout 20 edible lb per person. The traditionalsubsistence harvest area for Stevens Village isparticularly large, and the western portionintersects the TAPS (Figure D-22). Subsistenceconcerns identified during 1984 included habitatdestruction associated with the TAPS,competition for resources by nonlocal residents,and low moose populations (with no reasonproposed) (ADF&G 2001).

APPENDIX D D-108

TABLE D-24 Subsistence Harvest Summary for Stevens Village in 1984a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammalb 26 6,600 220.0 73.3 46.7 NA

Black bear 17 1,700 56.7 18.9 40.0 NA

Brown beard 2 −e − − 6.7 NA

Moose 7 4,900 163.3 54.4 20.0 NA

Small land mammal/furbearerb 1,856 1,856 61.9 20.6 73.3 NA

Beaver 14 210 7.0 2.3 13.3 NA

Foxd 40 − − − 30.0 NA

Hare 206 412 13.7 4.6 56.7 NA

Land otterd 1 − − − 3.3 NA

Lynxd 26 − − − 26.7 NA

Martend 432 − − − 46.7 NA

Minkd 8 − − − 10.0 NA

Muskrat 950 950 31.7 10.6 53.3 NA

Porcupine 3 24 0.8 0.3 10.0 NA

Wolverined 4 − − − 3.3 NA

FishesTotal fish 92,104 92,104 3,070.1 1,023.4 83.3 NA Total salmon 82,950 82,949 2,765.0 921.7 73.3 NA Total non-salmon 9,155 9,155 305.2 101.7 80.0 NA Burbot 80 280 9.3 3.1 40.0 NA Grayling 5 4 0.1 - 3.3 NA Pike 730 2,555 85.2 28.4 66.7 NA Sheefish 239 1,434 47.8 15.9 46.7 NA Sucker 53 111 3.7 1.2 23.3 NA Whitefish 2,511 4,771 159.0 53.0 73.3 NA

BirdsTotal bird and egg 1,761 1,761 58.7 19.6 90.0 NA Migratory bird 609 1,543 51.4 17.1 76.7 NA Crane 9 90 3.0 1.0 13.3 NA Duck 442 663 22.1 7.4 70.0 NA Goose 158 790 26.3 8.8 73.3 NA Upland game bird 311 218 7.3 2.4 76.7 NA Grouse 262 183 6.1 2.0 76.7 NA Ptarmigan 49 34 1.1 0.4 20.0 NA


D-109 APPENDIX D

TABLE D-24 (Cont.)


b Some not eaten.

c �NA� = data not available.

d Not eaten.



APPENDIX D D-110

D-111 APPENDIX D


FIGURE D-22 Subsistence Harvest Areas Associated with Stevens Village (DataSource: Sumida 1988)

D-113 APPENDIX D

D.3.3.22 Tanana

The village of Tanana lies about 2 mi west ofthe junction of the Tanana and Yukon Rivers,roughly 83 mi southwest of the TAPS(Figure D-3) (ADCED 2001). Located in a primesetting at the confluence of two major rivers inInterior Alaska, Tanana had served as animportant trading settlement for Athabascans inthe region long before the arrival of Europeans.The introduction of several amenities in andaround Tanana in about 1900 (including aschool-hospital complex, U.S. Army Fort Gibbon,a post office, and several trading posts) helpedto establish Tanana as the dominant communityin the region. The village has maintained thisrole throughout the 20th century and to thepresent. In 2000, the decennial census recorded308 inhabitants Tanana (see Table D-1). Theeconomy of Tanana is mixed, with a range ofwage-labor positions available, both full-time(with the city, village council, or school district)and seasonal (fire fighting, construction, andcommercial fishing). However, subsistencecontinues to play an important role, both insupplementing cash income and as a culturallyimportant activity.

Fishing dominated subsistence activities in1987, the reference year for Tanana, providingmore than 1,958 edible lb per capita. Most of thefish caught were salmon, but other species(notably whitefish) were used as well(Table D-25) (Andersen 1992; Betts 1997; Caseand Halpin 1990). Large land mammals alsoprovided considerable resources, on the order of141 edible lb per capita. Although smallmammals contributed much less to edibleresources, Tanana residents harvested a rangeof them for their fur. The majority of householdssurveyed in 1987 participated in subsistenceharvests of every resource category exceptsmall mammals and furbearers. Householdsusing these resources totaled 79% or more forall categories. All of those surveyed used largeland mammals. Although the subsistenceharvest area for Tanana does not intersect theTAPS, it does include long stretches of both theYukon and Tanana Rivers downstream from thepipeline that are used for fishing as well ashunting (Figure D-23). Subsistence concernsidentified during the late 1980s and late 1990sincluded habitat destruction due to mining;competition from nonlocal fishermen, hunters,and trappers for salmon, moose, and fur-bearinganimals; low moose population due to huntingcompetition and high wolf predation; and varyingseasonal availability of caribou (ADF&G 2001;Betts 1997).

APPENDIX D D-114

TABLE D-25 Subsistence Harvest Summary for Tanana in 1987a


Surveyed



PerCapita




Black bear 38 3,634 28.4 10.5 14.3 24.8

Brown bear 2 960 7.5 2.8 1.9 3.8

Caribou 40 3,961 30.9 11.5 12.1 30.2

Moose 57 40,050 312.9 11.8 35.1 100.0

Small land mammal/furbearerb 2,658 13,350 104.3 38.6 41.0 79.5

Beaver 379 11,357 88.7 32.8 12.8 57.4

Foxc 29 −d − − 11.5 12.4

Hare 891 1,781 13.9 5.2 32.6 43.8

Land otterc 14 − − − 2.8 3.7

Lynxc 34 − − − 9.0 12.7

Martenc 1,175 − − − 21.2 21.2

Minkc 37 − − − 6.2 6.2

Muskrat 64 167 1.3 0.5 5.3 6.2

Porcupine 6 44 0.4 0.1 4.3 8.1

Wolfc 5 − − − 3.7 5.6

Wolverinec 6 − − − 2.8 2.8

FishesTotal fish 119,394 677,209 5,290.7 1,958.4 76.7 93.2 Total salmon 86,554 553,266 4,322.4 1600.0 67.4 93.2 Total non-salmon 32,840 123,943 968.3 358.4 63.6 75.7 Burbot 370 370 2.9 1.1 26.7 22.7 Char 12 30 .2 0.1 0.9 0.9 Grayling 626 313 2.5 0.9 28.0 29.9 Pike 1,059 1,588 12.4 4.6 27.4 28.3 Sheefish 5,250 34,127 266.6 98.7 30.1 32.0 Sucker 605 302 2.4 0.9 12.2 12.2 Whitefish 24,918 87,212 681.3 252.2 32.0 50.9

BirdsTotal birds and egg 3,517 5,688 44.4 16.5 86.0 91.3 Migratory bird 1,424 3,710 29.0 10.7 45.4 64.6 Duck 794 1,191 9.1 3.4 36.7 55.0 Crane 12 47 0.4 0.1 3.4 3.4 Goose 618 2471 19.3 7.2 45.4 59.4 Upland game bird 2,094 1978 15.5 5.7 77.3 80.7 Grouse 1,515 1,515 11.8 4.4 77.3 80.7 Ptarmigan 579 463 3.6 1.3 77.3 80.7


D-115 APPENDIX D

TABLE D-25 (Cont.)


b Some not eaten.

c Not eaten.



APPENDIX D D-116

D-117 APPENDIX D


FIGURE D-23 Subsistence Harvest Areas Associated with Tanana (Data Source:ADF&G undated)

D-119 APPENDIX D

D.3.3.23 Tatitlek

Tatitlek is located on the Alaska mainland,on the shore of Prince William Sound in an areacalled the Tatitlek Narrows, roughly 17 misouthwest of the Valdez Marine Terminal(Figure D-3) (ADCED 2001). It is a historicAlutiiq village that residents moved to its presentlocation in about 1900. Following the 1964earthquake and tsunami, many residents ofChenega moved to Tatitlek. In 2000, thedecennial census recorded 107 people living inTatitlek (Table D-1). There are a few sources ofcash employment in Tatitlek (primarilycommercial fishing, fish processing, and small-scale oyster farming), but the most importanteconomic activity in the village is subsistence.

Residents of Tatitlek harvested a wide rangeof marine and land resources in 1997, therepresentative year for subsistence identified byADF&G (Table D-26) (Fall 1991; Stratton 1992;Stratton et al. 1996). Marine resources notably marine mammals and fish contributedthe greatest amounts of food to the householdssurveyed, accounting for 165 and 159 edible lbper capita, respectively. Although only half thehouseholds surveyed harvested marinemammals and three-fourths harvested fish,nearly 94% used marine mammals, and allhouseholds consumed fish; the widespreadimportance of these resources is evident. Marineinvertebrates, birds, and bird eggs were also

subsistence resources; again, the vast majorityof households studied used these resources.Small land mammals were harvested much lessoften and by only a small percentage ofcommunity residents, apparently for fur. Findingson the breadth of resources harvested wereconsistent with earlier research on the samecommunity, although the data for different yearsdemonstrate that considerable variability ispossible, even between successive harvestyears (Tomrdle and Miraglia 1993; see alsoStratton 1992). Although the traditionalsubsistence harvest area for Tatitlek does notintersect the TAPS, it does include severallocalities in Prince William Sound close to theValdez Marine Terminal (Figure D-24) (see alsoGanley 2001; Ganley and Wheeler 2000).Harvest areas for salmon, the only localities formarine species shown in Figure D-24, occur asclose as 2.6 mi from the terminal. Subsistenceconcerns identified during the late 1980s throughthe late 1990s included persisting problems dueto the Exxon Valdez oil spill; low populations ofseals, sea lions, some waterfowl, herring,sockeye salmon, a number of marineinvertebrates, and deer; and competition forsalmon and herring roe from nonresidents andcommercial operations (ADF&G 2001; Stratton1992). Studies focusing on subsistence changesfollowing the 1989 Exxon Valdez spill indicatethat declines indeed did occur for several yearsafter that event (Fall 1999).

APPENDIX D D-120

TABLE D-26 Subsistence Harvest Summary for Tatitlek in 1997a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Marine Mammals Marine mammalb 248 13,372 495.3 165.1 50.0 93.8

Porpoise 5 304 11.3 3.8 12.5 18.8

Sea otterc 57 −d − − 18.8 18.8

Seal 167 9,356 346.5 115.5 50.0 93.8

Steller sea lion 19 3,712 137.5 45.8 18.8 25.0

Terrestrial MammalsLarge land mammal 83 3,720 137.8 45.9 62.5 93.8 Deer 78 3,353 124.2 41.0 62.5 93.8 Goat 5 367 13.6 4.5 18.8 37.5

Small land mammal/furbearerb 24 − − − 12.5 12.5

Land otterc 24 − − − 12.5 12.5

Fishes and Marine InvertebratesTotal fish 12,858 12,858 476.2 158.7 75.0 100.0 Total salmon 1,375 7,552 279.7 93.2 68.8 100.0 Total non-salmon 5,306 5,306 196.5 65.5 62.5 81.3 Cod 94 302 11.2 3.7 31.3 31.3 Greenling 4 17 0.6 0.2 6.3 6.3 Halibut 2,008 2,008 74.4 24.8 43.8 68.8

Herringe 119 714 26.4 8.8 31.3 50.0

Herring roee 197 1,382 51.2 17.1 43.8 56.3 Rockfish 237 765 28.3 9.5 50.0 50.0 Sablefish 25 78 2.9 1.0 12.5 18.8

Smelte 12 38 1.4 0.5 12.5 31.3 Wolffish 2 1 − − 6.3 12.5


Chitone 26 104 3.8 1.3 25.0 50.0

Clame 158 474 17.6 5.9 56.3 56.3

Cocklee 51 153 5.7 1.9 25.0 25.0 Crab 407 652 24.1 8.1 31.3 68.8 Octopus 14 54 2.0 0.7 12.5 25.0

Oystere 19 56 2.1 0.7 12.5 43.8

Shrimpe 17 17 0.6 0.2 6.3 31.3

BirdsTotal bird and egg 1,750 797 29.5 9.8 68.8 81.3 Migratory bird 403 422 15.7 5.2 50.0 62.5 Crane 7 57 2.1 0.7 18.8 18.8 Duck 370 314 11.6 3.9 43.8 62.5 Goose 27 51 1.9 0.7 31.3 37.5

D-121 APPENDIX D

TABLE D-26 (Cont.)


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Upland game bird 12 8 0.3 0.1 12.5 12.5 Grouse 12 8 0.3 0.1 12.5 12.5 Bird egg 1,335 367 13.6 4.5 56.3 68.8


b Some not eaten.

c Not eaten.




APPENDIX D D-122

D-123 APPENDIX D


FIGURE D-24 Subsistence Harvest Areas Associated with Tatitlek (Data Source:ADF&G undated)

D-125 APPENDIX D

D.3.3.24 Tazlina

Tazlina is a small community located onTazlina River near its intersection with theCopper River, about 2 mi northeast of the TAPS(Figure D-3) (ADCED 2001). Tazlina wasoriginally an Ahtna Athabascan fish camp, andAlaska Natives had established a permanentvillage at this location by about 1900. Shortlythereafter, a roadhouse was constructed atTazlina, and another was built in the late 1920s,to take advantage of Tazlina�s location on themain trail north to Fairbanks. Copper ValleySchool, a boarding school built in the village andoperated until 1971, provided a basis for somevillage development. Despite its location on theRichardson Highway, Tazlina never grew verylarge. Its population in 2000 reached only149 persons (Table D-1). In part because ofTazlina�s location on a major highway and in partbecause of its proximity to the largest communityin the area (Glennallen, about 5 mi to the north),residents of Tazlina have more opportunities forcash income than do many rural Alaskans.Wage labor provides most of the livelihood forresidents of Tazlina, primarily throughemployment for local businesses or government

agencies that date largely to the TAPS period(Northern Land Use Research, Inc. 2000a).Subsistence persists as means ofsupplementing wage income.

Residents of Tazlina harvestedapproximately 100 edible lb of animal resourcesin 1987, the reference year defined by ADF&G(Table D-27) (Fall et al. 2001; National ParkService 1995; Simeone and Fall 1996; Strattonand Georgette 1985). About 56 edible lb of thistotal consisted of fish, with nearly 38 edible lb ofthe fish being salmon. Although only 63% of thehouseholds surveyed harvested salmon in 1987,nearly 94% consumed it. Large land mammalsmade up most of the remaining ediblesubsistence resources harvested, distributedamong six major species (moose and caribouaccounted for most of the harvest). A range ofsmall mammals were also harvested by Tazlinaresidents in 1987; the majority of species weretaken primarily for their fur. Subsistenceconcerns identified in 1987 included both habitatdestruction and potential increased competitionfor subsistence resources due to development inthe area (ADF&G 2001).

APPENDIX D D-126

TABLE D-27 Subsistence Harvest Summary for Tazlina in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 70 15,480 128.0 42.5 29.2 62.2 Bison 2 1,038 8.7 2.9 1.9 1.9 Black bear 5 365 3.0 1.0 3.8 10.1 Brown bear 1 343 2.9 0.9 1.0 1.0 Caribou 41 5,306 44.2 14.6 21.6 37.8 Dall sheep 2 150 1.3 0.4 1.9 12.0 Moose 18 8,278 69.0 22.7 14.4 28.7


Beaverc 27 −d − − 1.0 1.0

Coyotec 25 − − − 5.8 5.8

Foxc 29 − − − 6.7 6.7

Hare 228 342 2.9 0.9 14.8 16.8

Land otterc 2 − − − 1.9 1.9

Martenc 74 − − − 3.8 3.8

Minkc 13 − − − 1.0 1.0

Muskratc 24 − − − 1.0 1.0

Porcupine 94 423 3.5 1.2 10.1 10.1

Tree squirrelc 14 − − − 1.9 1.9

Weaselc 7 − − − 1.0 1.0

Wolfc 7 − − − 1.9 1.9

Fishes and Marine InvertebratesTotal fish 20,524 20,524 171.0 56.3 62.7 93.8 Total salmon 2,852 13,783 114.9 37.8 38.3 89.9 Total non-salmon 6,741 6,741 56.2 18.5 50.8 51.7 Burbot 265 363 5.3 1.7 11.5 13.4

Char 476 452 3.8 1.2 NAe NA Grayling 1,434 1,004 8.4 2.8 36.9 36.9 Halibut 3,629 3,629 30.2 10.0 15.3 38.3 Sucker 5 3 - - 3.8 3.8 Trout 537 758 6.3 2.1 NA NA Whitefish 288 259 2.2 0.7 10.6 14.4Marine invertebrate 368 368 3.1 1.0 12.0 12.0 Clam 368 368 3.1 1.0 12.0 12.0

BirdsTotal bird and egg 501 371 3.1 1.0 39.8 39.8 Migratory bird 96 168 1.4 0.5 6.7 6.7 Duck 66 49 0.4 0.1 6.7 6.7 Crane 16 97 0.8 0.3 1.9 1.9 Goose 14 22 0.2 0.1 1.9 1.9

D-127 APPENDIX D

TABLE D-27 (Cont.)


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Upland game bird 406 203 1.7 0.6 37.8 37.8 Grouse 261 130 1.09 0.36 27.8 27.8 Ptarmigan 145 73 0.60 0.20 20.6 20.6


b Some not eaten.

c Not eaten.


e NA = data not available.


APPENDIX D D-128

D.3.3.25 Tonsina

Tonsina is a small settlement in the centralCopper Basin, located about 2 mi east of theTAPS in the vicinity of PS 12 (Figure D-3 )(ADCED 2001). The village of Tonsina dates tothe beginning of gold mining in the area, at aboutthe turn of the 20th century. A roadhouse wasconstructed at the current location of Tonsina inabout 1900, along the Eagle-Valdez trail. AlaskaNatives from the region subsequently relocatedto Tonsina, possibly attracted to the roadhouselocality for trading or part-time employment.Despite additional developments, such as aU.S. Army telegraph station (constructed in1902) and a road connecting it to Chitina(constructed in 1910), Tonsina has not beeninhabited continually since its founding (NorthernLand Use Research, Inc. 2000a). The 2000census recorded 92 inhabitants in Tonsina(Table D-1). Much of the growth experienced inTonsina over the past three decades has beenrelated to the TAPS, a consequence of bothconstruction and continued operation. Mostadults in Tonsina work for wages, withemployment at PS 12 and on road maintenancecrews providing much of the income.Subsistence remains important, however, as ameans of supplementing the cash income ofmost households in the village.

Subsistence activities contributed nearly150 edible lb per capita to households surveyedin Tonsina in 1987, the representative year forsubsistence defined by ADF&G (Table D-28)(Fall et al. 2001; National Park Service 1995).Edible pounds per capita harvested were splitalmost equally between large land mammals andfish. Caribou and moose composed most of thelarge mammals by weight, although harvestsincluded seven species that year. Nearly 70% ofthe households surveyed participated in largegame harvests, with more than 90% using theresources obtained. By weight, the vast majorityof the fish harvested consisted of salmon; morethan 83% of the households surveyed harvestedfish, and nearly 92% used fish. Tonsinaresidents also harvested a wide range of smallmammals and furbearers; the majority wereused primarily for fur as opposed to meat. Part ofthe traditional subsistence harvest area forTonsina overlaps with a section of the TAPS(Figure D-25). In addition, the harvest area forthis community includes part of the Copper,Gulkana, and Klutina Rivers. Subsistenceconcerns identified during the late 1980sincluded both potential increased competition forresources and possible habitat destruction dueto development in the area (ADF&G 2001).

D-129 APPENDIX D

TABLE D-28 Subsistence Harvest Summary for Tonsina in 1987a


Surveyed


Units,Total


Harvest MeanPer


HouseholdsUsing

Terrestrial MammalsLarge land mammal 123 22,003 229.2 74.0 69.8 90.3 Black bear 7 296 3.1 1.0 4.1 13.8 Brown bear 1 −b − − 1.4 1.4

Caribou 75 9,743 101.5 32.8 63.7 75.8 Dall sheep 11 691 7.2 2.3 11.1 11.1 Deer 3 141 1.5 0.5 2.4 3.8 Goat 1 95 1.0 0.3 1.4 1.4 Moose 25 11,037 115.0 37.1 24.5 57.1


Beaver 12 − − − 10.4 10.4

Coyoted 15 − − − 1.0 2.1

Foxd 25 − − − 5.9 5.9

Hare 220 330 3.4 1.1 22.9 22.9

Land otterd 3 − − − 2.4 2.4

Marmotd 6 − − − 1.0 1.0

Martend 167 − − − 8.3 8.3

Minkd 27 − − − 2.1 2.1

Muskratd 5 − − − 1.0 1.0

Porcupine 16 72 0.8 0.2 11.1 11.1

Weaseld 14 − − − 1.4 1.4

Wolfd 14 − − − 3.5 3.5

Wolverined 8 − − − 1.0 1.0

Fishes and Marine InvertebratesTotal fish 21,729 21,729 226.4 73.1 83.3 91.7 Total salmon 4,028 19,238 200.4 64.7 63.9 83.3 Total non-salmon 2,492 2,492 26.0 8.4 67.1 69.8 Burbot 52 124 1.3 0.4 3.8 6.5 Char 803 878 9.1 3.0 24.8e 24.8e

Grayling 728 509 5.3 1.7 50.5 51.9 Halibut 536 536 5.6 1.8 3.8 25.9 Smelt 66 16 0.2 0.1 1.4 1.4 Whitefish 54 49 0.5 0.2 2.4 2.4

Marine invertebrate 326f 326f 3.4 1.1 2.1 10.4

Clam 300f 300f 3.1 1.0 1.0 1.0

Crab 21f 21f 0.2 0.1 1.0 1.0

Shrimp 5f 5f 0.1 − 1.0 9.4

APPENDIX D D-130

TABLE D-28 (Cont.)


Surveyed



PerCapita


HouseholdsUsing

BirdsTotal bird and egg 1,055 554 5.8 1.9 43.2 44.6 Migratory bird 105 79 0.8 0.3 9.6 9.6 Duck 103 76 0.8 0.3 9.6 9.6 Goose 3 3 − − 1.4 1.4

Upland game bird 949 475 4.9 1.6 41.8 43.2 Grouse 762 381 3.7 1.3 41.8 43.2 Ptarmigan 187 94 1.0 0.3 10.6 10.6



c Some not eaten.

d Not eaten.

e Data not recorded; data reported is the maximum of those recorded for subcategories.

f Unit of measure is pound.


D-131 APPENDIX D


FIGURE D-25 Subsistence Harvest Areas Associated with Tonsina (Data Source:ADF&G undated)

D-133 APPENDIX D

D.3.3.26 Wiseman

Wiseman is a small village located on thewestern bank of the middle fork of the KoyukukRiver, about 1 mi west of both the DaltonHighway and the TAPS (Figure D-3). Wisemanbegan as a single roadhouse built at theintersection of Wiseman Creek and the MiddleFork of the Koyukuk River in the early 1900s. Itgrew gradually between 1907 and 1912,populated primarily by people who wererelocating from nearby Coldfoot to be closer tolocal gold mines (Northern Land Use Research,Inc. 2000b). Population fluctuated over the yearsin the wake of continued small-scale gold miningin the area and, more recently, the constructionof the TAPS and Dalton Highway from 1974 to1976 and the formation of Gates of the ArcticNational Park and Preserve in 1980. In 2000, thepopulation of Wiseman was only 21 persons(Table D-1). Very little opportunity for wage laborexists in Wiseman beyond limited seasonal work(Scott 1998). As a result, subsistence is animportant activity in this small community.

Available subsistence harvest data from thestudy by Scott (1998) indicate that mosthouseholds participate in subsistence, with bothhunting and fishing providing key resources.Because the information in that study wasobtained by different methods than those usedby the ADF&G, its results are not strictlycomparable with the data in other tables in thisappendix that show species-specific harvestlevels. Wiseman data for 1991 indicate thatvillage residents harvested a range of mammals,fish, and birds (Table D-29). Caribou, hares,grayling, and upland game birds (grouse andptarmigan) were the most frequently harvestedresources in each of the main categoriespresented in the table. Large game made uponly about two-thirds of the harvest thatresidents felt would be necessary to meetcommunity food requirements. A large section ofthe subsistence harvest area for Wisemanintersects the TAPS (Scott 1998). Subsistence-related concerns expressed by Wisemanresidents included competition by nonlocalhunters (especially) and fishermen, constraintsplaced on subsistence activities by managinggovernment agencies, and declining resourcelevels (Scott 1998).

APPENDIX D D-134

TABLE D-29 Subsistence Harvest Summary forWiseman in 1991a

Subsistence ResourceNumber

Harvested

Preferred Total

Community Harvesta

Terrestrial MammalsLarge land mammal 20 31 Black bear 0 2 Caribou 10 12 Dall sheep 7 8 Grizzly bear 0 1 Moose 3 8

Small land mammal/furbearer 70 Nab

Hare 53 NA

Marmot −c NA Porcupine − NA

Squirrel 17 NA

FishesTotal fish 200 NA

Total salmond 31 NA Total non-salmon 169 NA Burbot 5 NA

Grayling 131e NA Pike 8 NA

Sheefishd 6 NA Trout 19 NA

BirdsTotal bird and egg 200 NA Migratory bird 31 NA Duck 17 NA Goose 14 NA Upland game bird 169 NA Grouse 96 NA Ptarmigan 73 NA

a Reflects harvest levels desired to meet food requirements.


c �−� = 0 or a number that rounds to 0.

d Non-local harvest.

e Actual number reported as range, 128−133; value shown is anaverage, rounded to the nearest whole fish.

Source: Compiled from data in Scott (1998).

D-135 APPENDIX D

D.5 REFERENCES FORAPPENDIX D

ADCED (Alaska Department of Community andEconomic Development), 2001, AlaskaCommunity Database: Detailed CommunityInformation. Available at http://www.dced.state.ak.us/mra/CF_BLOCK.cfm. AccessedDecember 7, 2001.

ADNR (Alaska Department of NaturalResources), 1993, Exxon Valdez Oil SpillBoundary, vector digital data, EVOS RestorationTeam, Anchorage, Alaska. Available atftp://www.dnr. state.ak.us/asgdc/evos/evosbnd.e00.gz. Accessed May 2002.

ADF&G (Alaska Department of Fish and Game),undated, geographic information system data forsubsistence harvest areas for assortedcommunities, from G. Jennings (ADF&G,Anchorage, Alaska) to L. Gorenflo (ArgonneNational Laboratory), Jan.

ADF&G, 1986, Alaska Habitat ManagementGuide, Arctic Region, Volume II: Distribution,Abundance, and Human Use of Fish andWildlife, Division of Habitat, Juneau, Alaska.

ADF&G, 2001, Community Profiles Database.Available at www.state.ak.us/local/akpages/FISH.GAME. Accessed Dec. 1, 2000.

Andersen, D., 1992, The Use of Dog Teams andthe Use of Subsistence-Caught Fish for FeedingSled Dogs in the Yukon River Drainage, Alaska,Technical Report No. 210, Alaska Department ofFish and Game, Juneau, Alaska.

Andrews, E., 1988, The Harvest of Fish andWildlife for Subsistence by Residents of Minto,Alaska, Technical Report No. 137, Division ofSubsistence, Alaska Department of Fish andGame, Juneau, Alaska.

Betts, M.F., 1997, Subsistence Harvest and UsePatterns for Rampart, Tanana, Stevens Village,Manley Hot Springs-Eureka, and Minto, Alaska,Alaska Department of Transportation and PublicFacilities, Fairbanks, Alaska.

Bieganski, D., 2001, geographic data forsubsistence harvest area for Nuiqsut, fromBieganski, BLM, Anchorage, Alaska), toL. Gorenflo (Argonne National Laboratory), Dec.

BLM (Bureau of Land Management), 2001,Identification of Tribes for Consultation for TAPSRenewal, Anchorage, Alaska.

Brannian, L.K., and D.G. Gnath, 1988,Subsistence Harvest of Pacific Salmon in theYukon River Drainage, Alaska, 1986 with anHistorical Review, Fishery ResearchBulletin 88-03, Alaska Department of Fish andGame, Division of Commercial Fisheries,Juneau, Alaska.

Brower, H.K., Jr., and R.T. Opie, 1997,Subsistence Harvest Documentation Project:Data for Nuuiqsut, Alaska, for the Period July 1,1994, to June 30, 1995, Department of WildlifeManagement, North Slope Borough, Barrow,Alaska, Jan.

Case, M., and L. Halpin, 1990, ContemporaryWild Resource Use Patterns in Tanana, Alaska,1987, Technical Paper No. 178, AlaskaDepartment of Fish and Game, Division ofSubsistence, Anchorage, Alaska.

Elanna, L.J., and G.K. Sherrod, 1984, The Roleof Kinship Links in Subsistence Production:Some Implications for Community Organization,Alaska Department of Fish and Game.

Fall, J.A., 1990, �The Division of Subsistence ofthe Alaska Department of Fish and Game: AnOverview of Its Research Program and Findings,1980−1990,� Arctic Anthropology 27(2):68−92.

Fall, J.A. (editor), 1991, Subsistence Harvestsand Uses in Seven Gulf of Alaska Communitiesin the Second Year following the Exxon ValdezOil Spill, Technical Paper No. 218, AlaskaDepartment of Fish and Game, Juneau, Alaska.

APPENDIX D D-136

Fall, J.A., 1999, �Changes in Subsistence Usesof Fish and Wildlife Resources following theExxon Valdez Spill,� pp. 51−103 in Evaluatingand Communicating Subsistence SeafoodSafety in a Cross-Cultural Context: LessonsLearned from the Exxon Valdez Oil Spill,L.J. Field et al. (editors), Society forEnvironmental Toxicology and Chemistry,Pensacola, Fla.

Fall, J., and L. Stratton, 1984, The Harvest andUse of Copper River Salmon: A BackgroundReport, Technical Report No. 96, AlaskaDepartment of Fish and Game, Juneau, Alaska.

Fall, J.A., and C.J. Utermohle (editors), 1995, AnInvestigation of the Sociocultural Consequencesof Outer Continental Shelf Development inAlaska, OCS Study MMS 95-012,U.S. Department of the Interior, MineralsManagement Service, Anchorage, Alaska.

Fall, J., et al., 2001, An Update of SubsistenceHarvest and Use Information for Communities inthe Copper River Basin, Technical ReportNo. 180, Alaska Department of Fish and Game,Division of Subsistence, Juneau, Alaska.

Federal Subsistence Board, 1999, SubsistenceManagement Regulations for the Harvest of Fishand Wildlife on Federal Public Lands in Alaska,U.S. Fish and Wildlife Service, Anchorage,Alaska.

Gubser, N.J., 1965, The Nunamiut Eskimo:Hunters of Caribou, Yale University Press,New Haven, Conn.

Holly, S., 1992, Taped Interview (16 September1992), Tape H93-15-40, Gates of the ArcticNational Park Project, Department of Alaska andPolar Regions, available at Rasmuson Library,University of Alaska-Fairbanks.

Hosley, E.H., 1981, �Intercultural Relations andCultural Change in the Alaska Plateau,�pp. 546−555 in Subarctic, Volume 6 ofHandbook of North American Indians, J. Helm(editor), Smithsonian Institute Press,Washington, D.C.

Impact Assessment, Inc., 1990, SubsistenceResource Harvest Patterns: Nuiqsut,U.S. Department of the Interior, MineralsManagement Service, Alaska Outer ContinentalShelf Region, Anchorage, Alaska.

Libby, D., et al., 1979, �Nuiqsut Synopsis,�pp. 151−166 in National Petroleum Reserve inAlaska: Native Livelihood and Dependence, AStudy of Land Use Values through Time, NorthSlope Borough Contract Staff (preparers),National Petroleum Reserve in Alaska WorkGroup 1, Field Study 1, North Slope Borough,Barrow, Alaska.

Marcotte, J., and T. Haynes, 1984,Contemporary Resource Use Patterns in theUpper Koyukuk Region, Alaska, Technical PaperNo. 93, Alaska Department of Fish and Game,Anchorage, Alaska.

McMillan, P.O., and S.V. Cuccarese, 1988,Alaska Over-the-Horizon Backscatter RadarSystem: Characteristics of ContemporarySubsistence Use Patterns in the Copper RiverBasin and Upper Tanana Area, Volumes I and II,Arctic Environmental Information and DataCenter in cooperation with Alaska Department ofFish and Game, Subsistence Division, andU.S. National Park Service, Anchorage, Alaska.

Mekiana, J., 1992, Taped Interview(15 December 1992), Tape H93-15-61, Gates ofthe Arctic National Park Project, Department ofAlaska and Polar Regions, Rasmuson Library,University of Alaska-Fairbanks. Available atRasmuson Library.

Moses, J., 1993, Taped Interview (April 1993),Gates of the Arctic National Park and PreserveProject, Department of Alaska and PolarRegions, tape H93-15-24, Rasmuson Library,University of Alaska-Fairbanks. Available atRasmuson Library.

National Park Service, 1995, Customary andTraditional Use Reference for Copper RiverBasin Area, U.S. National Park Service, AlaskaSystem Support Office, Anchorage, Alaska.

D-137 APPENDIX D

Nelson, R., 1992, Taped Interview(22 September 1992), Tape H93-15-30, Gates ofthe Arctic National Park Project, Department ofAlaska and Polar Regions, Rasmuson Library,University of Alaska-Fairbanks. Available atRasmuson Library.

North Slope Borough, 1999, 1998/99 EconomicProfile and Census Report, Department ofPlanning and Community Services, Barrow,Alaska.

North Slope Borough Planning Commission andCommission on History and Culture, 1979,Nuiqsut Heritage, Barrow, Alaska, Feb.

Northern Land Use Research, Inc., 2000a,Demographic, Economic, and SubsistenceProfiles of Thirteen Communities within and nearthe Copper River Basin, Fairbanks, Alaska.

Northern Land Use Research, Inc., 2000b,Trans-Alaska Pipeline System CommunityProfiles, Fairbanks, Alaska.

Northern Land Use Research, Inc., andVanguard Research, 1997, Subsistence Harvestand Use Patterns for Rampart, Tanana, StevensVillage, Manley Hot Springs-Eureka, and Minto,Alaska, prepared by Northern Land Use,Fairbanks, Alaska, and written by M. Betts,Vanguard, Sandpoint, Idaho, for Tryck NymanHayes, Inc., Anchorage, Alaska, and AlaskaDepartment of Transportation and PublicFacilities, Fairbanks, Alaska.

Olson, W.M., 1981, �Minto, Alaska,� pp. 707-711in Subarctic, Volume 6 of Handbook of NorthAmerican Indians, J. Helm (editor), SmithsonianInstitute Press, Washington, D.C.

Scott, C.P., 1998, Invitation to Dialogue: Landand Renewable Resource Use over Time inWiseman, Alaska, Technical ReportNPS/CCSOUW/NRTR-98-03, NPS D-31,College of Forest Resources, University ofWashington, Seattle, Wash.

Simeone, W., and J. Fall, 1996, Patterns andTrends in the Subsistence Fishery of the UpperCopper River, Alaska, Report to the AlaskaBoard of Fisheries, Division of Subsistence,Alaska Department of Fish and Game,Anchorage, Alaska, Dec.

Spearman, G., et al., 1979, �Anaktuvuk PassSynopsis,� pp. 121−140 in National PetroleumReserve in Alaska: Native Livelihood andDependence, A Study of Land Use Valuesthrough Time, North Slope Borough ContractStaff (preparers), National Petroleum Reserve inAlaska Work Group 1, North Slope Borough,Barrow, Alaska.

Stanek, R.T., 1985, Patterns of Wild ResourceUse in English Bay and Port Graham, Alaska,Technical Paper No. 106, Alaska Department ofFish and Game, Juneau, Alaska.

Stratton, L., 1983, Copper Basin Caribou Use: AResearch Update, Technical Report No. 75,Alaska Department of Fish and Game, Juneau,Alaska.

Stratton, L., 1989, Resource Uses in Cordova, ACoastal Community of Southcentral Alaska,Technical Report No. 153, Alaska Department ofFish and Game, Juneau, Alaska.

Stratton, L., 1992, Cordova: A 1988 Update onResource Harvests and Uses, Technical PaperNo. 204, Alaska Department of Fish and Game,Anchorage, Alaska, July.

Stratton, L., and E.B. Chisum, 1986, ResourceUse Patterns in Chenega, Western PrinceWilliam Sound: Chenega in the 1960s andChenega Bay 1984−1986, Technical PaperNo. 139, Alaska Department of Fish and Game,Anchorage, Alaska, Dec.

Stratton, L., and S. Georgette, 1984, Use of Fishand Game by Communities in the Copper RiverBasin, Alaska. A Report on a 1983 HouseholdSurvey, Technical Paper No. 107, AlaskaDepartment of Fish and Game, Anchorage,Alaska.

Stratton, L., and S. Georgette, 1985, CopperBasin Resource Use Map Index andMethodology, Technical Report No. 124, AlaskaDepartment of Fish and Game, Juneau, Alaska.

Stratton, L., et al., 1996, An Update onSubsistence Harvests in Chenega Bay andTatitlek in the Year following the Exxon ValdezOil Spill, Technical Paper No. 199, AlaskaDepartment of Fish and Game, Juneau, Alaska.

APPENDIX D D-138

Sumida, V., 1988, Land and Resource UsePatterns in Stevens Village, Alaska, TechnicalPaper No. 129, Alaska Department of Fish andGame, Division of Subsistence, Juneau, Alaska.

Sumida, V., and C. Alexander, 1985, MooseHunting by Residents of Beaver, Birch Creek,Fort Yukon, and Stevens Village in the WesternGMU 25(D) Permit Moose Hunt Area, 1984−85,Technical Paper No. 121, Alaska Department ofFish and Game, Juneau, Alaska.

Tomrdle, L., and R.A. Miraglia, 1993, Use of Fishand Wildlife in Valdez, Prince William Sound,Alaska, Chugach National Forest, U.S. ForestService, Anchorage, Alaska.

United Fishermen of Alaska, 2002, SubsistenceManagement Information, Management History,from Statehood to Present. Available athttp://www.subsistmgtinfo.org/history.htm.Accessed May 14, 2002.

U.S. Bureau of the Census, 2001, �Profiles ofGeneral Demographic Characteristics, 2000,Census of Population and Housing, Alaska,Washington, D.C., May.

USFWS (U.S. Fish and Wildlife Service), 2001,Subsistence Management for the Harvest ofWildlife on Federal Public Lands in Alaska,Office of Subsistence Management, Anchorage,Alaska.

Wolfe, R.J., 1996, �Subsistence Food Harvestsin Rural Alaska, and Food Safety Issues,� paperpresented at the National Academy of SciencesCommittee on Environmental Justice, Spokane,Wash., Aug. 13.

Wolfe, R.J., 2000, Subsistence in Alaska: A Year2000 Update, Alaska Department of Fish andGame, Division of Subsistence, Juneau, Alaska.

Wolfe, R.J., 2002, Frequently Asked Questions.Myths. What Have You Heard? Available athttp://www.state.ak.us/adfg/subsist/geninfo/about/subfaq.htm. Accessed June 13, 2002.

Wolfe, R.J., and R.J. Walker, 1987, �SubsistenceEconomies in Alaska: Productivity, Geography,and Development Impacts,� Arctic Anthropology24(2):56−81.

E-1

Appendix E:

ANILCA Section 810 Analysis ofSubsistence Impacts

APPENDIX E E-2

E-3

Appendix E:ANILCA Section 810 Analysis ofSubsistence Impacts

E.1 Subsistence Evaluation Factors

Section 810(a) of the Alaska NationalInterest Land Conservation Act (ANILCA)(16 USC Section 3120) requires that anevaluation of subsistence uses and needs becompleted as part of any federal agencydetermination to �withdraw, reserve, lease, orotherwise permit the use, occupancy, ordisposition of public lands.� As a consequence,an evaluation of potential subsistence impactsunder ANILCA Section 810 must be completedfor the TAPS ROW EIS. ANILCA requires thatthis evaluation include findings related to threespecific issues:

1. The effect of such use, occupancy, ordisposition on subsistence uses and needs;

2. The availability of other lands for thepurposes sought to be achieved; and

3. Other alternatives that would reduce oreliminate the use, occupancy, or dispositionof public lands needed for subsistencepurposes (16 USC Section 3120).

If an evaluation of the three issuesconcludes that an action may �significantlyrestrict subsistence uses,� ANILCA Section 810requires the head of the lead federal agency to:

• Notify the appropriate state agency, localcommittees, and regional councils(established under 16 USC Section 3115);

• Give notice of and hold a hearing in thevicinity of the area involved; and

• Determine that (1) such restriction tosubsistence is necessary and consistentwith sound management principles for use ofthe public lands in question, (2) theproposed activity will involve the minimalamount of public lands necessary toaccomplish its purposes, and (3) reasonable

steps will be taken to minimize adverseimpacts on subsistence uses and resources.

The following subsections in Appendix Econtain evaluations required by ANILCASection 810 for the proposed action, less-than-30-year renewal alternative, and no-actionalternative. They also contain the assessmentsof the cumulative impacts under ANILCASection 810. For each alternative and thecumulative case, the assessments considerthese five possible impact categories that couldrestrict the use of resources for subsistence:

1. A decline in the population or amount ofharvestable resources,

2. Changes in the geographic distribution ofsubsistence resources,

3. Competition for potential subsistenceresources,

4. Disturbance of subsistence activities, and

5. Constraints on access to subsistenceresources.

A significant restriction to subsistenceactivities might result from any of the above fiveimpacts, alone or in combination, should theyactually occur. Section 3.24 of this DEISprovides background on existing conditions forsubsistence in the vicinity of the TAPS. Thebackground information is augmented by a moredetailed discussion of existing conditions inAppendix D. Section 4.3.20 evaluatessubsistence impacts under the proposed action;Section 4.5.2.20 evaluates them under the less-than-30-year renewal alternative; andSection 4.6.2.20 evaluates them under the no-action alternative. Section 4.7.8.1 contains theevaluation of cumulative impacts onsubsistence. Finally, Appendix D presents

APPENDIX E E-4

summaries on these impacts that are discussedin detail in Section 4.

E.2 Evaluation of Impacts

E.2.1 Proposed Action

E.2.1.1 Evaluation

Section 4.3.20 identifies two problems thatlimit any attempt to evaluate the ultimate impactsof the proposed action. One is the inability toassign particular consequences to the TAPS asopposed to some other cause. The second is theinability to determine the net effects of potentialconsequences. Both of these problems relate tothe lack of the type of data that would providethe reliable, quantitative evidence necessary formaking conclusive final evaluations. Theconclusion reached in Section 4.3.20 is that anynegative impacts on subsistence from renewingthe TAPS ROW would be extremely small. Thisconclusion was based on the effects onsubsistence that could definitely be associatedwith renewing the TAPS. Renewal would:

• Limit access to (very small) parts of certaintraditional subsistence harvest areas and

• Result in continued use of the DaltonHighway, along with various access roadsand airspace over the TAPS, to maintainTAPS operations and continued humanactivity around the TAPS possiblydisrupting the movement of small numbersof terrestrial mammals.

As discussed in Section E.1, a significantrestriction to subsistence uses could result fromfive impact categories, either alone or incombination. These impacts can be assessedwith regard to the proposed action:

1. A decline in the population or amount ofharvestable resources. As noted inSections 3.18 through 3.22, there is noevidence that there has been a decline inthe populations or amounts of harvestableresources as a result of current operation ofthe TAPS, apart from effects on individualor very small numbers of animals. The

populations of certain caribou herds haveincreased, some substantially, during theperiod of TAPS operation (TAPS Owners2001), although this population growth isnot necessarily a consequence of pipelineoperation. As a result, there is noanticipated impact with regard to thisimpact category.

2. Changes in the geographic distribution ofsubsistence resources. One of the mostfrequently cited concerns about the currentand potential future operation of the TAPSexpressed by subsistence practitioners isthe adverse impacts on the geographicdistribution of subsistence resources(Sections 3.24.1 and D.3.3). Theimplications of such changes would bereduced accessibility; for instance, althoughpopulations of key resources might belarger, they might not be as accessible forharvest as they were in the past. Availableevidence does indicate that caribou, inparticular, are sensitive to human activity,including movement on foot or in varioustypes of vehicles (Horejsi 1981; Murphyand Lawhead 2000; Tyler 1991; Wolfe et al.2000). However, there is no evidence fromconventional scientific studies that theTAPS, or activity in the TAPS ROW or onthe Dalton Highway in support of the TAPS,have affected herd movement at apopulation level (Sections 4.3.15, 4.3.16,and 4.3.17) (TAPS Owners 2001). Verysmall numbers of caribou, moose, andother key subsistence resources may altertheir movement patterns, and hencepossibly their geographic distribution, as aconsequence of the TAPS and the humanactivity required to maintain it, but there isno evidence that such changes in behaviorwould have more than a negligible effect onsubsistence activities.

3. Competition for potential subsistenceresources. Another frequently cited concernabout the current and future operation ofthe TAPS is competition from nonlocalswho harvest fish and game that mightotherwise be harvested for localsubsistence (Sections 3.24.1 and D.3.3).One of the causes proposed to explain thiscompetition is increased access to remote

E-5 APPENDIX B

areas, primarily as a consequence ofopening the Haul Road/Dalton Highway tothe public. TAPS service roads also arecited as providing increased access toremote areas. Although it is indisputablethat opening the Dalton Highway to publicuse provided increased access to a largepart of north-central Interior Alaska, whichpossibly led to increased hunting andfishing in this part of the state (Haynes2000), the Dalton Highway is now owned,operated, and maintained by the State ofAlaska, and it would remain so regardlessof the outcome of the decision on whetherto renew the TAPS ROW. Service roads,however, are related directly to the TAPS,and their continuation is directly related tothe ROW renewal. Moreover, they providefurther access to subsistence resources.However, the amount of access theyprovide is limited because of their relativelyshort length, the size of the vast AlaskaInterior and subsistence harvest areas(Figure 3.24-1), and further constraints ontheir use following the events of September11, 2001. Thus, access-related competitionwith nonlocals for subsistence resourceseither is not related to the TAPS ROWrenewal or appears to have greatlimitations. Claims that TAPS employeescompete for fish and game in areas theyare familiar with as a result of their work onthe TAPS could certainly be true, but dataare lacking, and no evidence exists tosuggest that this source of competition (ifpresent) is large. If competition related tothe TAPS would have an adverse impact onsubsistence, the magnitude of this impactlikely would be very small.

4. Disturbance of subsistence activities.Disturbance of subsistence activities due tothe TAPS refers primarily to the presence ofTAPS-related activities or nonlocalsinterfering with subsistence hunting andfishing. This interference could take theform of activities associated with theoperation of the TAPS vehicular orairplane movement, maintenance activities,etc. interfering with subsistenceharvesting. It also could involve thepresence of other nonlocals whosepresence or actions somehow adversely

affect subsistence activities. As discussedabove (see impact category 2), humansand human activities have been shown tointerfere with the behavior of game.However, TAPS-related sources of suchinterference are limited to the ROW, whichrepresents a very small portion of thesubsistence-harvest areas concerned; as aconsequence, interference should besimilarly limited. Although many morepeople may have access to previouslyremote portions of Alaska, thereby actingas possible sources of interference withsubsistence activities, as discussed above(see impact category 3), most of theincrease in access relates to the DaltonHighway which would not close even ifthe TAPS was terminated. Impacts throughdisturbance of subsistence activities eitherappear to be geographically quite limited orare not related to the TAPS. As aconsequence, once again, any negativeimpacts from ROW renewal likely would benegligible.

5. Constraints on access to subsistenceresources. Continued operation of theTAPS could lead to limitations on access tosubsistence areas relative to restrictions onhunting and fishing in certain areas. Suchrestrictions exist in the ROW as a means ofprotecting both TAPS personnel and TAPSinfrastructure. However, for many of thecommunities possibly affected by theTAPS, such restrictions do not involve anyof their traditional harvest areas(Figures 3.24-1 and D-5 through D-25). Forthose communities whose subsistenceareas intersect the TAPS (Section 3.24-1),restrictions would be very small comparedwith the size of the harvest regions inquestion. Thus, although there would beconstraints on access to subsistenceresources, at least in certain areas, theimpacts of these constraints would likely bevery small by virtue of the proportion ofsubsistence harvest area affected.

E.2.1.2 Findings

Impacts of the proposed action onsubsistence would not reach the threshold of�may significantly restrict� subsistence uses. As

APPENDIX E E-6

discussed in the preceding section, four of thefive impact categories might occur under ROWrenewal. Those impacts likely to be related to theTAPS would be (1) limiting access tosubsistence harvest areas and (2) possiblydisrupting the movement of game. However, it islikely that the effects of both impacts would bevery small, such that neither one wouldsignificantly restrict subsistence uses.

E.2.2 Less-Than-30-YearRenewal Alternative

E.2.2.1 Evaluation

Anticipated impacts under the less-than-30-year renewal alternative are discussed inSection 4.5.2.20. The evaluation of the less-than-30-year alternative for purposes of ANILCASection 810 considers the five potential impactcategories defined in Section E.1 to determine ifthis alternative would lead to significant impactson subsistence uses. As discussed inSection 4.5.2.20, impacts associated with theless-than-30-year renewal alternative generallywould be less than those associated with theproposed action. For the impacts considered inthe ANILCA Section 810 evaluation:

1. Any changes in the population ofsubsistence resources would be smaller.

2. Changes in the geographic distribution ofsubsistence resources would have lesstime to accumulate, thereby likely resultingin smaller shifts.

3. Impacts from competition would have lesstime to accumulate, although theconsequences of competition in any givenperiod of time (e.g., year) could be thesame as those under the proposed action.

4. Impacts from disturbance would have lesstime to accumulate, although, once again,the consequences of disturbance in anygiven period of time could be the same asthose under the proposed action.

5. Impacts from constraints on access wouldhave less time to accumulate, althoughimpacts for any particular period could be

the same as those under the proposedaction.

E.2.2.2 Findings

Impacts of the less-than-30-year-renewalalternative on subsistence would not reach thethreshold of �may significantly restrict�subsistence uses. As discussed in the precedingsection, although any of the five impactcategories might occur under ROW renewal,their magnitudes generally would be smallerthan they would be under the proposed action.Once again, impacts likely related to the TAPSconsist of limiting access to subsistence harvestareas and possibly disrupting the movement ofgame. However, the effects of both impactslikely would be very small, such that neither onewould significantly restrict subsistence uses.

E.2.3 No-Action Alternative

E.2.3.1 Evaluation

Section 4.6.2.20 concluded that any impactsto subsistence under the no-action alternativelikely would be slightly positive. This conclusionwas tentative, hampered in part by the inability toassociate consequences specifically with theTAPS and the inability to estimate the magnitudeof various impacts, positive or negative.Deciding upon a slightly positive impact wasbased on a qualitative evaluation of possibleresults from discontinuing the TAPS. On the onehand, the population of Alaska is anticipated toincrease slightly under the no-action alternative,with much of the increase coming from AlaskaNatives (Tables 4.6-12 and 4.6-15) who havetraditionally pursued subsistence more thanhave other groups in Alaska. Economicconditions resulting from discontinuation of theTAPS likely would yield slight declines inpersonal income (Table 4.6-16), possiblycreating a greater impetus to pursuesubsistence. Declines in personal income mightmake it more difficult to purchase the moderntechnology often used in subsistence activitiesas well as in recreational hunting and fishing,and it might reduce the number of individualsengaged in the latter because of otherassociated costs. Finally, the no-actionalternative would remove some existing

E-7 APPENDIX B

restrictions on subsistence activities near theTAPS, as well as reduce human activity on theDalton Highway, on TAPS access roads, andnear various TAPS facilities, which might have avery slight effect on the movement of certainsubsistence resources (Section 4.3.20).

A consideration of key impact categoriesused to evaluate the presence of significantrestrictions under ANILCA Section 810 similarlyyields mixed results:

1. A decline in the population or amount ofharvestable resources. There is no clearevidence that harvestable resources woulddecline as a direct consequence of the no-action alternative. It is possible that anincrease in the population of AlaskaNatives, coupled with increased economicimpetus to pursue subsistence, might yieldincreased pressure on subsistenceresources. However, as noted inSections 3.18 through 3.22, with theexception of certain threatened andendangered species, the populations of fishand game appear to be adequate to sustainthemselves and reasonable harvests.Moreover, subsistence activities accountfor a relatively small amount, on the orderof 2%, of all fish and game harvested inAlaska (Wolfe 2000).

2. Changes in the geographic distribution ofsubsistence resources. As noted above,discontinuing the TAPS would eliminateTAPS-related traffic on the Dalton Highway,TAPS access roads, and near TAPSfacilities, which might have a slight effecton the movement of small numbers ofterrestrial mammals important tosubsistence. There is no evidence that anydisruption to movement at population levelshas occurred as a result of TAPS operation;thus, the removal of possible causes wouldlikely have only a small positive effect.

3. Competition for potential subsistenceresources. Two types of competition canoccur: competition from recreationalhunting and fishing and competition fromsubsistence activities. Under the no-actionalternative, it is likely that the former sourceof competition would decline slightly, whilethe latter would increase. It is unclear if the

net effect would be positive or negative, butit probably would be small.

4. Disturbance of subsistence activities.Disturbance of subsistence activities wouldprobably decline under the no-actionalternative. This conclusion is based, inpart, on (1) an anticipated small decline inpersonal income in Alaska, which mightreduce the number of state residentstraveling to remote areas in the state, and(2) a possible decline in the amount ofmaintenance on the Dalton Highwaybecause of reduced state revenues, whichwould make it more difficult to use thehighway. Increased tourism by non-Alaskans could compensate for anyreduction in travel by Alaskans within thestate, but the possibility of that situationoccurring is uncertain. Moreover, anydeterioration in the condition of the DaltonHighway would not affect the potentialdisruption of subsistence activities in otherareas where that transportation link is not akey means of general regional access.

5. Constraints on access to subsistenceresources. Restrictions to subsistenceharvest areas likely would decline underthe no-action alternative. Many areaswhere hunting and fishing are not permittedbecause of the presence of TAPS facilitiesand TAPS-related activities would be madeavailable to subsistence activities onceagain. However, as noted in Section 4.3.20,current restrictions involve relatively smallareas compared with the large subsistenceharvest areas used by communitiesconsidered in this EIS (Figures 3.24-1 andD-5 through D-25), if they involve anyportion of those harvest areas at all.

E.2.3.2 Findings

Impacts of the no-action alternative onsubsistence would not reach the threshold of�may significantly restrict� subsistence uses. Asdiscussed in the preceding section, individualimpacts are anticipated to be small and likelywould be slightly positive overall.

APPENDIX E E-8

E.2.4 Cumulative Impacts

Section 4.7.8.1 summarized cumulativeimpacts to subsistence associated with theproposed action, less-than-30-year renewalalternative, and no-action alternative. Anticipatedcumulative negative impacts associated with theless-than-30-year renewal alternative werejudged to be less than those associated with theproposed action, while impacts associated withthe no-action alternative were presented as thesmallest of all three cumulative cases. Allnegative impacts were felt to be small, with theexception of certain consequences undercumulative impacts associated with theproposed action and less-than-30-year renewalalternative. This conclusion was tentative,hampered in part by an inability to associateconsequences specifically with the TAPS and aninability to estimate the magnitude of variousimpacts, positive or negative. The conclusionarrived at was based on a qualitative comparisonof all likely consequences of past, present, andreasonably foreseeable actions in a broadgeographic area affected by the TAPS organizedinto three subregions: the North Slope, InteriorAlaska, and Prince William Sound area. In allcases, the contributions from the TAPS to thecumulative impacts appeared to be relativelysmall when compared with the contributions fromthe other actions.

This section of Appendix E evaluates thecumulative impacts of the TAPS in the context ofANILCA Section 810. The discussion is dividedinto three subsections, dealing with cumulativeimpacts associated with the proposed action,less-than-30-year renewal alternative, and no-action alternative. The conclusions reached arethat cumulative impacts associated with eachalternative might significantly restrictsubsistence uses. Although at first glance theseconclusions may seem inconsistent with theconclusions presented in the main body of theEIS under cumulative impacts (Section 4.7.8.1),they are based in part on the reduced amount ofcertainty embodied in the phrase �maysignificantly restrict.�

E.2.4.1 Cumulative ImpactsAssociated with theProposed Action

E.2.4.1.1 Evaluation. As discussed inSection E.1, a significant restriction tosubsistence uses may result from five categoriesof impacts, either alone or in combination. Thesecan be assessed with regard to cumulativeimpacts associated with the proposed action.

1. A decline in the population or amount ofharvestable resources. As noted inSections 3.18 through 3.22, there is noevidence that a decline in the populationsor amounts of harvestable resources hasresulted from current operation of the TAPSand other current actions in the TAPSROW, apart from effects on individual orvery small numbers of animals. Indeed, thepopulations of certain caribou herds haveincreased, some substantially, during theperiod of TAPS operation (TAPS Owners2001), although this population growth isnot necessarily a consequence of pipelineoperation. Some of the actions consideredas contributing cumulative impacts alreadyare in place and apparently have notled to any population declines in keysubsistence resources. Other cumulativeactions (e.g., additional oil exploration,development, and production and theconstruction and operation of a natural gaspipeline), although not yet in place, aresimilar to those currently in operation andthus would not be anticipated to yield largenegative impacts. As a result, there is noanticipated impact under this impactcategory.

2. Changes in the geographic distribution ofsubsistence resources. As noted above,one of the most frequently cited concernsabout the current and potential futureoperation of the TAPS expressed bysubsistence practitioners is the adverseimpacts on the geographic distribution ofsubsistence resources (Sections 3.24.1 andD.3.3). The implication of such changeswould be reduced accessibility. Eventhough populations of key resources mightbe larger, they might not be as accessible

E-9 APPENDIX B

for harvesting as they were in the past.Available evidence does indicate thatcaribou, in particular, are sensitive tohuman activity, including movement on footor in various types of vehicles (Horejsi1981; Murphy and Lawhead 2000; Tyler1991; Wolfe et al. 2000). There is noevidence from conventional scientificstudies that the TAPS or activity in theTAPS ROW or on the Dalton Highway insupport of the TAPS has affected herdmovement at a population level. Impactsidentified are often temporary and confinedto a few animals (Sections 4.3.15, 4.3.16,4.3.17, and E.2.1.1) (TAPS Owners 2001).However, additional activity presumablywould add to the disruption of gamemobility, particularly on the North Slope,where many of these activities would beconcentrated. The amount of disruptioncannot be quantified given the presentknowledge about locations of specificactivities, but changing the movements oflarge numbers of animals with respect totraditional harvest areas would haveimportant implications for subsistence.

3. Competition for potential subsistenceresources. Also frequently cited as aconcern with regard to both the current andfuture operation of the TAPS, competition,in this case, involves nonlocals harvestingfish and game that might otherwise beharvested for local subsistence(Sections 3.24.1 and D.3.3). One of thecauses of this competition is increasedaccess to remote areas, primarily as aconsequence of opening transportationlinks, such as the Dalton Highway, to thepublic. However, service roads also arecited as providing increased access toremote areas. Additional service roadswould accompany oil and gas exploration,development, and production on the NorthSlope and the construction andmaintenance of a natural gas pipeline,thereby providing further (although likelylimited) access. The degree to which TAPSemployees compete for fish and game inareas they are familiar with as a result ofworking on the TAPS is uncertain.Furthermore, although more individualswould become familiar with remote parts of

Alaska because of their association withthese additional activities, their contributionto competition cannot be estimated atpresent. If cumulative impacts associatedwith the proposed action were present, theirmagnitude likely would be small.

4. Disturbance of subsistence activities.Disturbance of subsistence activities fromcumulative actions refers primarily to thepresence of activities or nonlocals interferingwith subsistence hunting and fishing. Thisinterference could take the form of activitiesassociated with the construction or operationof the other facilities use of heavyequipment, vehicular or airplane traffic,maintenance activities, etc. It also couldinvolve the presence of other nonlocals(e.g., tourists, indirect support personnel)whose presence or actions somehowadversely affect subsistence activities. Asdiscussed above (see impact category 2),human activities have been shown tointerfere with the behavior of certainanimals. Moreover, access to remote areaswould likely increase because of reasonablyforeseeable actions (see impact category 3).Nevertheless, cumulative impacts in theform of disturbance to subsistence activitieslikely would be geographically limited to theareas associated with cumulative actions.As a consequence, any negative impactslikely would be small.

5. Constraints on access to subsistenceresources. The construction and operation ofother facilities in addition to the TAPS wouldlead to placing limits on access tosubsistence areas or placing restrictions onhunting and fishing in certain areas. Suchrestrictions would provide a means ofprotecting the personnel and infrastructureassociated with the cumulative actions.Although for many of the communitiesexamined in this document, current andreasonably foreseeable future actions do notand would not involve any of their traditionalharvest areas (Figure 3.24-1), in somecases, restrictions would affect these areas.Traditional harvest areas tend to be large,and restricted areas likely would becomparatively small. Relative impacts fromrestricted access would be greatest on the

APPENDIX E E-10

North Slope, where activities contributing tocumulative impacts would be most heavilyconcentrated, and would include thesubsistence harvest areas for AnaktuvukPass and Nuiqsut (Figures 3.24-1, D-6, andD-19). Despite the ability of the residents ofthese two communities to pursuesubsistence in other, unrestricted portions oftheir traditional subsistence harvest areas,because of their need to pursue game whereand when it occurs, in some circumstances,cumulative restrictions could significantlyrestrict subsistence uses.

E.2.4.1.2 Findings. Cumulative impactsassociated with the proposed action onsubsistence meet the threshold of �maysignificantly restrict� subsistence uses. Asdiscussed in the preceding section, an increasein potential disruption of subsistence resourcemovement, and an increase in the area closed tosubsistence, might hamper subsistenceactivities.

E.2.4.2 Cumulative ImpactsAssociated with theLess-Than-30-YearRenewal Alternative

E.2.4.2.1 Evaluation. The evaluation ofcumulative impacts associated with the less-than-30-year renewal alternative is generally thesame as the evaluation of cumulative impactsassociated with the proposed action justdiscussed (Section 2.4.1.1). This similarityreflects, in part, the relative importance ofimpacts from other actions when compared withimpacts from the TAPS and, in part, theresemblance of subsistence impacts from theTAPS under the entire 30-year and the less-than-30-year renewal periods. Evaluation of thefive categories of impacts is repeated here.

1. A decline in the population or amount ofharvestable resources. As noted inSections 3.18 through 3.22, there is noevidence that a decline in the populationsor amounts of harvestable resources hasresulted from current operation of the TAPSand other current actions in the TAPS

ROW, apart from effects on individual orvery small numbers of animals. Thepopulations of certain caribou herds haveincreased, some substantially, during theperiod of TAPS operation (TAPS Owners2001), although this population growth isnot necessarily a consequence of pipelineoperation. Some of the actions consideredas contributing cumulative impacts arealready in place and apparently have notled to any population declines in keysubsistence resources. Other cumulativeactions (e.g., additional oil exploration,development, and production and theconstruction and operation of a natural gaspipeline), although not yet in place, aresimilar to those currently in operation andthus would not be anticipated to yield largenegative impacts. As a result, there is noanticipated impact under this impactcategory.

2. Changes in the geographic distribution ofsubsistence resources. As noted above,one of the most frequently cited concernsabout the current and potential futureoperation of the TAPS expressed bysubsistence practitioners is the adverseimpacts on the geographic distribution ofsubsistence resources (Sections 3.24.1 andD.3.3). The implications of such changeswould be reduced accessibility. Eventhough populations of key resources mightbe larger, they might no longer be asaccessible for harvesting as they were inthe past. Available evidence does indicatethat caribou, in particular, are sensitive tohuman activity, including movement on footor in various types of vehicles (Horejsi1981; Murphy and Lawhead 2000; Tyler1991; Wolfe et al. 2000). There is noevidence from conventional scientificstudies that the TAPS or activity in theTAPS ROW or on the Dalton Highway insupport of the TAPS has affected herdmovement at a population level. Impactsthat have been identified are oftentemporary and confined to a few animals(Sections 4.3.15, 4.3.16, 4.3.17, andE.2.1.1) (TAPS Owners 2001). However,added activity presumably would add to thedisruption of game mobility, particularly onthe North Slope, where many of these

E-11 APPENDIX B

activities would be concentrated. Theamount of disruption cannot be quantifiedgiven the present knowledge about thelocations of specific activitites, butchanging the movements of large numbersof animals with respect to traditionalharvest areas would have importantimplications for subsistence.

3. Competition for potential subsistenceresources. Also frequently cited as aconcern about the current and futureoperation of the TAPS, competition, in thiscase, involves nonlocals harvesting fishand game that might otherwise beharvested for local subsistence(Sections 3.24.1 and D.3.3). One of thecauses of this competition is increasedaccess to remote areas, primarily as aconsequence of opening transportationlinks, such as the Dalton Highway, to thepublic. However, service roads also arecited as providing increased access toremote areas. Additional service roadswould accompany oil and gas exploration,development, and production on the NorthSlope and the construction andmaintenance of a natural gas pipeline,thereby providing further (although likelylimited) access. The degree to which TAPSemployees compete for fish and game inareas they are familiar with as a result ofworking on TAPS is uncertain. Althoughmore individuals would become familiarwith remote parts of Alaska because of theirassociation with cumulative actions, theircontribution to competition cannot beestimated at present. If cumulative impactsassociated with the less-than-30-yearrenewal alternative were present, theirmagnitude likely would be small.

4. Disturbance of subsistence activities.Disturbance of subsistence activities fromcumulative actions refers primarily to thepresence of activities or nonlocalsinterfering with subsistence hunting andfishing. This interference could take theform of activities associated with theconstruction or operation of the otherfacilities use of heavy equipment,vehicular or airplane traffic, maintenanceactivities, etc. It also could involve the

presence of other nonlocals (e.g., tourists,indirect support personnel) whose presenceor actions somehow adversely affectsubsistence activities. As discussed above(see impact category 2), humans andhuman activities have been shown tointerfere with the behavior of certainanimals. Moreover, access to remote areaswould likely increase due to reasonablyforeseeable actions (see impactcategory 3). Nevertheless, cumulativeimpacts in the form of disturbance tosubsistence activities likely would begeographically limited to the areasassociated with cumulative actions. As aconsequence, any negative impacts likelywould be small.

5. Constraints on access to subsistenceresources. The construction and operationof other facilities in addition to the TAPSwould lead to limitations on access tosubsistence areas or restrict hunting andfishing in certain areas. Such restrictionswould provide a means of protectingpersonnel and infrastructure associatedwith the cumulative actions. Although formany of the communities examined in thisdocument, current and reasonablyforeseeable future actions do not involveany of their traditional harvest areas(Figure 3.24-1), in some cases, restrictionswould affect these areas. Traditionalharvest areas tend to be large, andrestricted areas likely would becomparatively small. Relative impacts fromrestricted access would be greatest on theNorth Slope, where cumulative actionswould be most heavily concentrated, andwould include the subsistence harvestareas for Anaktuvuk Pass and Nuiqsut(Figures 3.24-1, D-6, and D-19). Despitethe ability of the residents of these twocommunities to pursue subsistence inother, unrestricted portions of theirtraditional subsistence harvest areas,because of their need to pursue gamewhere and when it occurs, in somecircumstances, cumulative restrictionscould significantly restrict subsistenceuses.

APPENDIX E E-12

E.2.4.2.2 Findings. Cumulative impactsassociated with the less-than-30-year renewalalternative on subsistence meet the threshold of�may significantly restrict� subsistence uses. Asdiscussed in the preceding section, an increasein potential disruption of subsistence resourcemovement and an increase in the area closed tosubsistence might hamper subsistenceactivities.

E.2.4.3 Cumulative ImpactsAssociated with theNo-Action Alternative

E.2.4.3.1 Evaluation. The mixedimpacts of the no-action alternative onsubsistence, with some consequences likelypositive and others likely negative, would alsooccur for the cumulative impacts under theno-action alternative. The population of Alaska isanticipated to increase slightly under theno-action alternative, with much of the increasecoming from Alaska Natives (Tables 4.6-12 and4.6-15), who have traditionally pursuedsubsistence more than other groups in the state.Moreover, economic conditions resulting fromdiscontinuation of the TAPS likely would yieldslight declines in personal income(Table 4.6-16), possibly creating a greaterimpetus to pursue subsistence. Declines inpersonal income might make it more difficult topurchase the modern technology often used forsubsistence activities as well as recreationalhunting and fishing, and they might reduce thenumber of individuals engaged in the latterbecause of other associated costs. Finally, theno-action alternative would remove someexisting restrictions on subsistence activitiesnear the TAPS and on human activity on theDalton Highway, TAPS access roads, and nearvarious TAPS facilities, which might have a veryslight effect on the movement of certainsubsistence resources (Section 4.3.20). Thisanalysis assumes that other, future actionswould continue even if the TAPS was closed,despite the close relationship between thepipeline system and the reduced utility orfeasibility of certain other activities (e.g., NorthSlope oil exploration, development, andproduction) should the TAPS cease to exist.

A consideration of key impacts used toevaluate the presence of significant restrictionsunder ANILCA Section 810 similarly yieldsmixed results:

1. A decline in the population or amount ofharvestable resources. There is no clearevidence that harvestable resources woulddecline as a direct consequence of the no-action alternative. It is possible that anincrease in the Alaska Native population inAlaska, coupled with increased economicimpetus to pursue subsistence, might yieldincreased pressure on subsistenceresources. However, as noted inSections 3.18 through 3.22, with theexception of certain threatened andendangered species, the populations of fishand game appear to be adequate to sustainthemselves and reasonable harvests.Moreover, subsistence activities harvest arelatively small amount, on the order of 2%,of all fish and game harvested in Alaska(Wolfe 2000). Increases in fish and gameharvests by the relatively slight populationgrowth associated with other current andreasonably foreseeable future actionswould have little effect on subsistenceresource populations.

2. Changes in the geographic distribution ofsubsistence resources. As noted above,discontinuing the TAPS would eliminateTAPS-related traffic on the Dalton Highway,TAPS access roads, and near TAPSfacilities, which might have a slight effecton the movement of small numbers ofterrestrial mammals important tosubsistence. There is no evidence that anydisruption to their movement at populationlevels has resulted from TAPS operations;thus, the removal of possible causes likelywould have only a small positive effect. Anypositive effect would be reduced orremoved by the increase of traffic andhuman activity in support of other,cumulative actions. However, once again,negative impacts on the distribution ofsubsistence resources are not anticipatedat a population level.

3. Competition for potential subsistenceresources. Two types of competition canoccur: competition from recreational

E-13 APPENDIX B

hunting and fishing and competition fromsubsistence activities. Under the no-actionalternative alone, it is likely that the formersource of competition would declineslightly, while the latter would increase. Theaddition of effects from cumulative actionslikely would increase the amount ofrecreational hunting and fishing, therebycountering the reduction in these activitiesanticipated to accompany the termination ofthe TAPS. However, these increases likelywould be slight. It is unclear if the net effectwould be positive or negative, but itprobably would be small.

4. Disturbance of subsistence activities.Disturbance of subsistence activities isexpected to decline under the no-actionalternative. This conclusion is based in parton an anticipated small decline in personalincome in Alaska, which might reduce thenumber of state residents traveling toremote areas in the state, and in part on apossible decline in the amount ofmaintenance on the Dalton Highwaybecause of reduced state revenues, whichwould make it more difficult to use thehighway. The addition of cumulative actionscould partially counter these declines,although it probably would not compensatefor them completely. Increased tourism bynon-Alaskans could compensate for anyreduction in travel by Alaskans within thestate, but the likelihood of such an increaseis uncertain. Moreover, any deterioration inthe condition of the Dalton Highway wouldnot affect the potential disruption ofsubsistence activities in other areas wherethat transportation link is not a key meansof general regional access.

5. Constraints on access to subsistenceresources. Although restrictions tosubsistence harvest areas likely woulddecline under the no-action alternative,when other current and reasonablyforeseeable actions are considered, the neteffect likely would be an increase inrestrictions to these areas. Relative impactsfrom restricted access would be greatest onthe North Slope, where cumulative actionswould be most heavily concentrated; thisarea includes the subsistence harvest

areas for Anaktuvuk Pass and Nuiqsut(Figures 3.24-1, D-6, and D-19). Despitethe ability of the residents of these twocommunities to pursue subsistence inother, unrestricted portions of theirtraditional subsistence harvest areas,because of their need to pursue gamewhere and when it occurs, in somecircumstances, cumulative restrictionscould significantly restrict subsistenceuses.

E.2.4.3.2 Findings. Cumulative impactsassociated with the no-action alternative onsubsistence meet the threshold of �maysignificantly restrict� subsistence uses. Asdiscussed in the preceding section, an increasein potential disruption of subsistence resourcemovement and an increase in the area closed tosubsistence might hamper subsistenceactivities.

E.3 References forAppendix E

Haynes, T.L., 2000, Subsistence Information forAlyeska Pipeline Service CompanyEnvironmental Report, Alaska Department ofFish and Game, Division of Subsistence,Fairbanks, Alaska, Nov.

Horejsi, B.L., 1981, �Behavioral Response ofBarren Ground Caribou to a Moving Vehicle,�Arctic 34:180−185.

Murphy, S.M., and B.E. Lawhead, 2000,�Caribou,� pp. 59−84 in The Natural History of anArctic Oil Field: Development and the Biota,J.C. Truett and S.R. Johnson (editors),Academic Press, San Diego, Calif.

TAPS Owners (Trans Alaska Pipeline SystemOwners), 2001, Environmental Report for TransAlaska Pipeline System Right-of-Way Renewal(Draft), Anchorage, Alaska.

Tyler, B.L., 1991, �Short-Term BehavioralResponses of Svalbard Reindeer Rangifertarandus platyrhynchus to Direct Provocation bya Snowmobile,� Biological Conservation56:179−194.

APPENDIX E E-14

Wolfe, R.J., 2000, Subsistence in Alaska: A Year2000 Update, Alaska Department of Fish andGame, Division of Subsistence, Juneau, Alaska.

Wolfe, S., B. Griffith, and C. Wolfe, 2000,�Response of Reindeer and Caribou to HumanActivities,� Polar Research 19(1):63−73.

F-1

Appendix F:

Agreement and Grant of Right-of-Wayfor Trans-Alaska Pipeline

APPENDIX F F-2

APPENDIX F

Agreement and Grant ofRight-of-Way for Trans-Alaska Pipeline

betweenThe United States of America

andAmerada Hess Pipeline Corporation,

BP Pipelines (Alaska) Inc.,Exxon Mobil Pipeline Company,

Phillips Transportation Alaska, Inc.,Unocal Pipeline Company, and

Williams Alaska Pipeline Company, L.L.C.

Table of ContentsSection Page1. Grant of Right-of-Way.................................... 22. Purpose of Grant; Limitation of Use

to Permittees............................................... 33. Transportation of Oil ...................................... 34. Exhibits; Incorporation of Certain

Documents by Reference ........................... 35. Width of Right-of-Way.................................... 46. Location of Right-of-Way ............................... 47. Duration of Right-of-Way Grant ..................... 58. Use Charge for Right-of-Way ........................ 59. Construction Plans and Quality

Assurance Program .................................... 510. Compliance with Notices to Proceed ............. 611. Reservation of Certain Rights to the

United States .............................................. 612. Reimbursement of Department Expenses..... 713. Damage to United States Property; Repair,

Replacement or Claim for Damages........... 914. Indemnification of the United States .............. 1015. Guaranty........................................................ 1016. Laws and Regulations ................................... 1117. No Right of Set Off......................................... 1118. Right of United States to Perform .................. 1219. Liens .............................................................. 1320 Insolvency...................................................... 1321. Breach; Extent of Liability of Permittees ........ 1322. Transfer ......................................................... 1423. Port Valdez Terminal Facility ......................... 1524. Duty of Permittees to Abate........................... 1825. Temporary Suspension Orders of

Authorized Officer ....................................... 18

Section Page26. Appeal Procedure.......................................... 1927. Requests to Resume; Appeals ...................... 2028. Nondiscrimination and Equal

Employment Opportunity ............................ 2129. Training of Alaska Natives............................. 2330. Native and Other Subsistence ....................... 2331. Termination or Suspension of

Right-of-Way............................................... 2332. Release of Right-of-Way................................ 2533. Agreements Among Permittees..................... 2534. Access to Documents .................................... 2735. Rights of Third Parties ................................... 2736. Covenants Independent ................................ 2737. Partial Invalidity ............................................. 2738. Waiver Not Continuing................................... 2739. Remedies Cumulative; Equitable Relief ........ 2840. Section Headings .......................................... 2841. Authority to Enter Agreement ........................ 28Exhibit A. Federal Grant of Right-of-Way

F-12505 and AA-5847 Legal Description ......... A-1Exhibit B. Requirements of the Department of

Defense Relating to Military Installations.......... B-1Exhibit C. Requirements of the Federal Power

Commission Relating to Power Sites................ C-1Exhibit D. Stipulations for the Agreement and

Grant of Right-of-Way for the Trans-AlaskaPipeline............................................................. D-1

Exhibit E. Cooperative Agreement betweenUnited States Department of the Interior andState of Alaska Regarding the ProposedTrans-Alaska Pipeline System.......................... E-1

APPENDIX F

APPENDIX F

1

Agreement and Grant of Right-of-Wayfor Trans-Alaska Pipeline

This Agreement and Grant of Right-of-Way(hereinafter referred to as the "Agreement")* isentered into as of this 23rd day of January, 1974(hereinafter referred to as the "Effective Date"),by the United States of America, party of the firstpart (hereinafter referred to as the "UnitedStates�), acting through the Secretary of theInterior, and by

Amerada Hess Pipeline Corporation,BP Pipelines (Alaska) Inc.,Exxon Mobil Pipeline Company,Phillips Transportation Alaska, Inc.,Unocal Pipeline Company, andWilliams Alaska Pipeline Company, L.L.C.

parties of the second part (hereinaftersometimes referred to as the "OriginalPermittees").

The parties have entered into thisAgreement taking into consideration the nationalauthorizations, directives, and policiesexpressed in applicable legislation, includingSection 202 of the Trans-Alaska PipelineAuthorization Act, 87 Stat. 584, et seq. (1973).

It is the intent of the parties that, in theperformance of this Agreement, the followingprinciples shall apply:

(1) In the construction (including, but notlimited to, design), operation,maintenance (including but not limited toa continuing and reasonable program ofpreventive maintenance) andtermination of the Pipeline System,Permittees shall employ all practicablemeans and measures to preserve andprotect the environment, as provided inthis Agreement.

(2) The parties shall balance environmentalamenities and values with economicpracticalities and technical capabilities,so as to be consistent with applicable

*NOTE. Terms having special meaning are

defined in the body of this Agreement or in Exhibit Dhereof. Such terms are capitalized herein.

national policies. In so doing, theparties shall take into account, amongother considerations, the following:

(a) The benefit or detriment to persons,property and the environment thatmay be anticipated to result from aproposed course of conduct;

(b) The particular environmental,technical, and economical benefitsor detriments reasonably expectedto flow from a proposed course ofconduct;

(c) The effect on the energy needs ofthe United States, including thepossible effects of a disruption ofnational or regional oil supply, thatmay result from a particular courseof conduct.

(3) Permittees shall manage, supervise andimplement the construction, operation,maintenance and termination of thePipeline System in accordance withsound engineering practice, to the extentallowed by the state of the art and thedevelopment of technology. In theexercise of these functions, Permitteesconsent and shall submit to such review,inspection and compliance proceduresrelating to construction, operation,maintenance and termination of thePipeline System as are provided for inthis Agreement and other applicableauthorizations. The Parties intend thatthis Agreement shall not in any wayderogate from, or be construed as beinginconsistent with, the provisions ofSection 203(d) of the Trans-AlaskaPipeline Authorization Act, 87 Stat. 585(1973), relating to the NationalEnvironmental Policy Act, 83 Stat. 852,42 U.S.C. § 4321 et seg.

In consideration of the grant hereby made,and the provisions of this Agreement, theUnited States and Permittees agree as follows:

APPENDIX F

2

l. Grant of Right-of-Way

A. Pursuant to the provisions of the Trans-Alaska Pipeline Authorization Act, the UnitedStates hereby grants to Permittees in the severalundivided interests specified in subsection B ofthis Section, for the period of limited durationprescribed in Section 7 hereof and for thepurpose prescribed in subsection A of Section 2hereof, a right-of-way (hereinafter referred to asthe "Right-of-Way"), the width and locationthereof being subject to the provisions ofSections 5 and 6 hereof, across, through andupon the Federal Lands (as that term is definedin Section 28 of the Mineral Leasing Act of 1920,41 Stat. 449, as amended, 30 U.S.C. § 185 etSeq., including public and acquired lands, andlands withdrawn, reserved, classified, orotherwise set apart for National Forests, militarypurposes, power development, or otherpurposes) along the route of the Pipeline,identified in the applications as amended and asdescribed in Exhibit A hereof.

B. The grant made hereby is of thefollowing undivided interests in and to the Right-of-Way:

Amerada Hess Pipeline Corporation, anundivided interest of 1.5000% of thewhole;

BP Pipelines (Alaska) Inc., an undividedinterest of 46.9263% of the whole;

ExxonMobil Pipeline Company, an undividedinterest of 20.3378% of the whole;

Phillips Transportation Alaska, Inc., anundivided interest of 26.7953% of thewhole;

Unocal Pipeline Company, an undividedinterest of 1.3561% of the whole; and

Williams Alaska Pipeline Company, L.L.C.an undivided interest of 3.0845% of thewhole.

C. There is hereby excepted from the granthereby made all lands selected and validlytentatively approved to the State of Alaska,pursuant to the Alaska Statehood Act, 72 Stat.339, as amended, other than lands withdrawnunder Section 11(a)(2) of the Alaska NativeClaims Settlement Act, 85 Stat. 696, 43 USC §1610.

D. There is hereby reserved to the UnitedStates all rights reserved, or directed to bereserved, to the United States under anyapplicable law or regulation of the United Statesor elsewhere under this Agreement.

E. The grant hereby made is subject to:(1) the provisions of this Agreement; (2) allapplicable laws and regulations of theUnited States; (3) any valid existing rights in thelands subject to the Right-of-Way, includingwithout limitation the valid pre-existing rights, ifany, of the State of Alaska; and (4) the conditionthat the Right-of-Way granted hereby acrossCategory l(c) Lands and Category 1(d) Lands*shall take effect upon the occurrence of one ofthe following events, whichever shall first occur:

(a) The Commissioner of NaturalResources of the State of Alaska notifiesthe Secretary in writing that it isessential for the expeditiousconstruction of the Pipeline System thatthe Right-of-Way in and to some or all ofthe Category 1(c) Lands orCategory 1(d) Lands, or both, becomeseffective;** or

(b) Category 1(d) Lands have not beententatively approved to the State ofAlaska and a valid right-of-way lease orother grant in and to those lands has notbeen issued by the State of Alaska, forthe construction and operation of thePipeline System, by March 10, 1974; or

(c) The Category 1(e) Lands have not beententatively approved to the State ofAlaska and a valid right-of-way lease orother grant in and to those lands has notbeen issued by the State of Alaska, forthe construction and operation of thePipeline System, by June 1, 1974.

* �Category 1(c) Lands" and "Category 1(d) Lands"

are defined in Exhibit D hereto. These terms arederived from Paragraph 1 of Part I of the CooperativeAgreement between the State of Alaska and theDepartment, attached hereto as Exhibit E forinformational purposes.

**The Secretary has received notice from the StateCommissioner of Natural Resources that theexpeditious construction of the Pipeline System onthe Category 1(d) Lands is essential. Therefore, theRight-of-Way across those lands in hereby effective.

APPENDIX F

3

F. With respect to the Category 1(c) Landsand the Category 1(d) Lands, the grant herebymade is further subject to the limitation andcondition that upon either valid tentativeapproval or valid patent of any of such lands tothe State of Alaska, the existence or subsequentissuance of a valid State right-of-way lease orother grant in and to those lands terminates theRight-of-Way and other Federal authorizations, ifany, and the State right-of-way lease or othergrant thereupon applies in all respects to thoselands.

G. Permittees agree that they will notchallenge the validity of the State�s right-of-waylease or other grant on the basis of the existenceof the Federal Right-of-Way and otherauthorizations or their interest therein.

2. Purpose of Grant; Limitation of Useto Permittees

A. The Right-of-Way is granted for thepurpose of the construction, operation, andmaintenance of one (1) Oil transportationpipeline, consisting of one (1) line of forty-eight(48)-inch diameter pipe and its Related Facilities(such pipeline and Related Facilities beingherein referred to as the "Pipeline").

B. Permittees, their agents, contractors,and subcontractors (at any tier) shall not use theRight-of-Way or the land subject thereto for anyother purpose and shall not locate or constructany other pipelines (including looping lines) orother improvements, within the Right-of-Waywithout the prior written approval of theSecretary.

C. The Pipeline shall be used for only thetransportation of Oil, and it shall not be used forany other purpose without the prior writtenapproval of the Secretary.

D. Each Permittee shall not allow or sufferany Person or Business Entity, with theexception of the other Permittees under thisAgreement, to use the Right-of -Way for thepurpose set forth in subsection A of this Section.

E. Nothing above in subsection D of thisSection is intended to: (1) excuse or precludePermittees from complying with their obligationsunder Section 3 of this Agreement, or

(2) preclude Permittees from employing agents,contractors, or subcontractors (at any tier) toeffect construction, operation, maintenance ortermination of the Pipeline System.

3. Transportation of Oil

Each Permittee shall, to the extent of itsinterest in the Right-of-Way, and in accordancewith the provisions of Section 28 of the MineralLeasing Act of 1920, 41 Stat. 449, as amended:

(1) Construct, operate, and maintain thePipeline as a common carrier;

(2) Accept, convey, transport, or purchasewithout discrimination, Oil delivered tothe Pipeline without regard to whethersuch Oil was produced on Federal ornon-Federal lands; and

(3) Accept, convey, transport, or purchase,without, discrimination, Oil producedfrom Federal Lands or from theresources thereon in the vicinity of thePipeline in such proportionate amountsas the Secretary may, after a full hearingwith due notice thereof to Permitteesand a proper finding of facts, determineto be reasonable.

4. Exhibits; Incorporation of CertainDocuments by Reference

A. The Exhibits that are attached to thisAgreement and that are listed below in thissubsection are, by this reference, incorporatedinto and made a part of this Agreement as fullyand effectually as if the Exhibits were set forthherein in their entirety:

(1) Federal Grant of Right-of-Way F-12505and AA-5847 Legal Description,attached hereto as Exhibit A.

(2) Requirements of the Department ofDefense relating to military installations,with attached letters datedNovember 14, 1973, and November 23,1973, from the Director of Real Estate,Department of the Army, Office of theChief of Engineers, attached hereto asExhibit B.

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(3) Requirements of the Federal PowerCommission relating to power sites,attached hereto as Exhibit C.

(4) Stipulations for the Agreement andGrant of Right-of-Way for the Trans-Alaska Pipeline, being numbered1 through 3.11.2, inclusive, attachedhereto as Exhibit D, which aresometimes referred to in this Agreementas the "Stipulations.�

B. The cooperative agreement attachedhereto as Exhibit E is not incorporated into, andis not intended to be made a part of, thisAgreement. Said cooperative agreement isattached hereto only for informational purposes.

5. Width of Right-of-Way

The width of the Right-of-Way, in terms ofsurface measurement, is fifty (50) feet plus theground occupied by the Pipeline; provided,however, that up to and including the date onwhich Permittees may file an application formodification of the Right-of-Way boundaries inaccordance with subsection D of Section 6hereof, Permittees may apply for, and theAuthorized Officer may direct or authorize,increases in the width of the Right-of-Way atspecified points if he finds, and records thereasons for his finding, that in his judgment awider Right-of-Way is necessary for operationand maintenance of the Pipeline afterconstruction, or to protect the environment orpublic safety.

6. Location of Right-of-Way

A. The site for each Construction Segmentof the Pipeline shall be determined inaccordance with the provisions ofStipulation 1.7.

B. After completion of construction of thePipeline within a particular Mapping Segment,the Federal Lands subject to the Right-of-Wayshall be the land occupied by the Pipeline and, interms of surface measurement, twenty-five (25)feet on each side of the Pipeline measured fromits outermost extremities. With respect toRelated Facilities, the width shall be twenty-five(25) feet around the perimeter of the RelatedFacility.

C. Upon completion of construction of thePipeline within a Mapping Segment, as well asupon the issuance of any authorization ordirective that the Authorized Officer may issue inaccordance with the provisions of Section 5hereof, Permittees shall, if directed by theAuthorized Officer, physically mark on theground the proposed boundaries of the Right-of-Way at such locations and in such manner as isacceptable to the Authorized Officer.

D. At any time prior to the sixtieth (60th)day preceding the filing of the maps of survey asprovided in subsection E hereof, Permittees mayfile an application for modification of the Right-of-way boundaries provided that, aftermodification, the Right-of-Way will include theground occupied by the Pipeline plus fifty (50)feet adjacent thereto and such additional land asauthorized by the Authorized Officer pursuant toSection 5 hereof. Upon approval of suchapplication for modification of boundaries andacceptance of the documents and maps requiredby subsection E hereof, the Right-of-Way shallbe as delineated on said maps of survey.

E. Within three hundred and sixty (360)days after the date of Commissioning of thePipeline (and, in the case of any addition,deletion or alteration of the Pipeline following thedate of Commissioning, within one hundred andeighty (180) days after the addition, deletion oralteration has, in the judgment of the AuthorizedOfficer, been fully completed), Permittees shallsurvey and provide adequate monumentation tolocate and describe the Right-of-Way and shallfile: (1) proof of construction of the Pipeline inaccordance with the applicable regulations of theDepartment; (2) such documents ofrelinquishment of land not included in themodified Right-of-Way, if any, as may berequired by the Authorized Officer;(3) appropriate references to applications inwhich requests were made for Right-of-Waywidths greater than the normal limitationsspecified in Section 5 of this Agreement, andapplications for modification of the Right-of-Wayboundaries as provided in subsection D hereof;and (4) a map, or maps of survey, prepared insuch manner as shall be required by theAuthorized Officer, showing the final "as built"location of the completed Pipeline, including thefinal locations of all buried and above ground

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improvements, the centerline of the Right-of-Way, as definitely located, and, referenced to thecenterline, the boundaries of the Right-of-way,as definitely located. Each portion of thePipeline as depicted on the said survey map ormaps, and for which a Notice to Proceed, or anauthorization, issued in accordance, withStipulation 1.7.4.4 altering either the route or theinitially approved location along the route of theRight-of-Way, has been issued, shall bereferenced to the relevant Notice to Proceed orauthorization.

7. Duration of Right-of-Way Grant

A. The grant hereby made of the Right-of-Way shall come to an end and expire on the22nd day of January, 2004, at noon,Washington, D.C. time, unless prior thereto it isrelinquished, abandoned, or otherwiseterminated pursuant to the provisions of thisAgreement or of any applicable Federal law orregulation.

B. Upon the expiration of the initial or anysubsequent grant of the Right-of-Way, or itsearlier relinquishment, abandonment, or othertermination, the provisions of this Agreement, tothe extent applicable, shall continue in effect andshall be binding on the parties hereto, theirsuccessors or assigns, until they have fullyperformed their respective obligations andliabilities accruing before or on account of theexpiration, or the prior termination, of the grant.

C. The Right-of-Way shall be renewed,subject to and in accordance with the provisionsof the Trans-Alaska Pipeline Authorization Act.

D. Any subsequent conveyance, transfer orother disposition of any right, title or interest inthe Federal Lands or any part thereto, burdenedby and subservient to the Right-of-Way, shall, tothe extent allowed by law and subject to thetermination provision of subsection F of Section1, be subject to the Right-of -Way and theprovisions of this Agreement, includingPermittees' right to renew the Right-of-Wayunder subsection C of this Section.

8. Use Charge for Right-of-Way

A. Permittees shall pay to the UnitedStates, annually and in advance, the fair market

rental value of the Right-of-Way, as determinedby the Secretary. (Such rental value ishereinafter called the "Use Charge".)

B. The initial Use Charge shall be OneHundred Five Thousand and 00/100 Dollars($105,000) for each calendar year. The firstannual Use Charge shall be prorated to coverthat portion of the calendar year 1974 whichremains after the Effective Date hereof and shallbe due and payable by not later than theEffective Date hereof. The Use Charge for thefirst full calendar year commencing after theEffective Date hereof and for each subsequentcalendar year shall be due and payable by notlater than the last full business day immediatelypreceding the first day of January of the calendaryear for which the Use Charge is payable. TheUse Charge for each calendar year shall bebilled to Permittees at least thirty (30) days inadvance of the due date thereof. All suchpayments shall be delivered to the AuthorizedOfficer and shall be accepted subject tocollection.

C. The Use Charge for the seventh (7th)and for each succeeding calendar year shall besubject to adjustment from time to time inaccordance with the regulations of theDepartment. The Secretary also may adjustretroactively the amount of the annual UseCharge for any calendar year that is based on anappraisal which is made before the Right-of-Wayis, in its entirety, finally located, surveyed andmonumented; any sum determined by theSecretary to be payable (by either the UnitedStates or Permittees) in connection with anadjustment, as provided for in this sentence,shall be due and payable within thirty (30) daysafter notice is given of the amount due.

9. Construction Plans and QualityAssurance Program

A. Permittees shall submit construction(including design) plans, a quality assuranceprogram, and other related documents asdeemed necessary by the Authorized Officer, forreview and approval prior to his issuing Noticesto Proceed.

B. The quality assurance program shall becomprehensive and designed to assure that theenvironmental and technical Stipulations in this

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Agreement will be fully complied with throughoutall phases of construction, operation,maintenance and termination of the PipelineSystem.

C. The following criteria shall be included inthe quality assurance program, althoughPermittees are not limited to these criteria:

(1) Provide adequate and appropriatemeans and procedures for the detectionand prompt abatement of any actual orpotential condition that is susceptible toabatement by Permittees which arisesout of, or could affect adversely, theconstruction, operation, maintenance ortermination of all or any part of thePipeline System and which at any timemay cause or threaten to cause: (a) ahazard to the safety of workers or topublic health or safety (including but notlimited to personal injury or loss of lifewith respect to any person or persons)or (b) serious and irreparable harm ordamage to the environment (includingbut not limited to areas of vegetation ortimber, fish or other wildlife populations,or their habitats, or any other naturalresource).

(2) Provide adequate and appropriatemeans and procedures for the repair andreplacement of improved or tangibleproperty and the rehabilitation of naturalresources (including but not limited torevegetation, restocking fish or otherwildlife populations and reestablishingtheir habitats) that shall be seriouslydamaged or destroyed if the immediatecause of the damage or destructionarises in connection with, or resultsfrom, the construction, operation,maintenance or termination of all or anypart of the Pipeline System.

(3) Provide for component and systemsquality through adequate quality controlmanagement and planning, andinspection and test procedures.

(4) Assure that the selection of Permittees�contractors, subcontractors and contractpurchases of materials and services are

based upon the above quality controlprocedures.

(5) Determine quality performance byconducting surveys and field inspectionsof all of the facilities of Permittees�contractors and subcontractors.

(6) Maintain quality determination recordson all of the above procedures to insuresatisfactory data identification andretrieval.

10. Compliance with Notices toProceed

All construction of the Pipeline Systemundertaken by Permittees shall comply in allrespects with the provisions of Notices toProceed that are issued by the AuthorizedOfficer.

11. Reservation of Certain Rights tothe United States

A. The United States reserves and shallhave a continuing and reasonable right ofaccess to any part of the lands (including the,subsurface of, and the air space above, suchlands) that are subject to the Right-of-Way, anda continuing and reasonable right of physicalentry to any part of the Pipeline, for inspection ormonitoring purposes and for any other purposeor reason that is reasonably consistent with anyright or obligation of the United States under anylaw or regulation, this Agreement, or any otheragreement, permit or authorization relating inwhole or in part to all or any part of the Pipeline.

B. The rights of access and entry reservedin subsection A of this Section shall extend toand be enjoyed by any contractor of theUnited States, any subcontractors (at any tier) ofthe contractor and their respective agents andemployees, as well as such other persons, asmay be designated from time-to-time in writingby the Authorized Officer.

C. There is reserved to the United Statesthe right to grant additional permits oreasements for rights-of-way to third parties forcompatible uses on, or adjacent to, the landssubject to the Right-of-Way. Before the UnitedStates grants an additional right-of-way or permit

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for a compatible use, the United States will notifyPermittees of its intentions and shall consult withPermittees before taking final action in thatregard.

12. Reimbursement of DepartmentExpenses

A. Permittees shall reimburse the UnitedStates for all reasonable administrative andother costs heretofore or hereafter incurreddirectly or indirectly by the Department for: (1)processing applications filed by Permittees inconnection with the Pipeline System; and (2)monitoring the construction, operation,maintenance, and termination of all or any partof the Pipeline System, including withoutlimitation those portions of the System that shallbe located on State-owned lands.

B. Subject to collection, receipt is herebyacknowledged by the Department of the sum ofTwelve Million Two Hundred Fifty ThreeThousand Seven Hundred Thirty and 00/100Dollars ($12,253,730) which has been paid tothe United States by Permittees at the time ofexecution of this Agreement. Said sumrepresents the amount of the costs referred to insubsection A of this Section, which wereincurred by the Department through September30, 1973.

C. Permittees shall hereafter pay to theUnited States such sums as the Secretary shalldetermine to be required to reimburse theDepartment for the costs, referred to insubsection A of this Section, incurred or to beincurred by it subsequent to September 30,1973. Such payments shall be made inaccordance with the provisions of subsection Fof this section.

D. Permittees acknowledge that theDepartment has employed or may employ one ormore independent consultants, contractors andsubcontractors and also has utilized and mayutilize personnel and services of other agenciesto assist it with: (1) processing applicationsheretofore or hereafter filed by Permittees inconnection with the Pipeline System; and (2)monitoring the construction, operation,maintenance and termination of the PipelineSystem. Before employing such consultants,contractors, or subcontractors, the Secretary

shall notify Permittees of such employment andshall inform the Permittees of the purpose ofemployment, the scope of the work to beundertaken, the duration of the employment andthe estimated cost thereof; provided, however,this notice requirement shall not limit theauthority of the Secretary to enter intoagreements with consultants, contractors orsubcontractors. Costs incurred by theDepartment in connection with the employmentof consultants, contractors and subcontractorsand with respect to utilizing the personnel andservices of other agencies shall be included inthe costs for which the Department is to bereimbursed by Permittees under the provisionsof subsection A of this Section.

E. Agreements entered into by theSecretary with respect to the Pipeline Systemwhich result in costs for which reimbursement isrequired by this Section shall be drawn to avoidunnecessary employment of personnel andneedless expenditure of funds. The Departmentshall administer this Agreement and such otheragreements to reasonably assure thatunnecessary employment of personnel andneedless expenditure of funds are avoided.

F. Reimbursement by Permittees, asprovided for in this Section and Section 18hereof, shall be made for each quarter ending onthe last day of March, June, September andDecember. On or before the sixtieth (60th) dayafter the close of each quarter, the AuthorizedOfficer shall submit to Permittees a writtenstatement of the costs incurred by theDepartment during that quarter which arereimbursable.

G. Permittees shall have the right toconduct, at their own expense, reasonableaudits by auditors or accountants, designated byPermittees, of the books, records anddocuments of the Department and of itsindependent consultants, contractors andsubcontractors relating to the items on anyparticular statement, that shall be submitted inaccordance with the procedure outlined insubsection F of this Section, at the places wheresuch books, records and documents are usuallymaintained and at reasonable times; provided,however, that written notice of a desire toconduct such an audit must be given theAuthorized Officer: (1) at least fifteen (15) days

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prior to such audit; and (2) by not later than theseventy-fifth (75th) day after the close of thequarter for which the books, records anddocuments are sought to be audited; andprovided further, that any such audits shall becompleted within ninety (90) days after receiptby Permittees of the statement containing theitems to be audited.

H. Nothing herein shall be deemed torequire the Department, its bureaus or offices, orits independent consultants, contractors andsubcontractors to maintain books, records ordocuments other than those usually maintainedby them, provided that such books, records anddocuments reasonably segregate and identifythe costs for which reimbursement is required bythis Section. Such books, records anddocuments shall be preserved or caused to bepreserved for a period of at least two (2) yearsafter the Department submits a statement forreimbursement based on such books, recordsand documents. The auditors or accountantsdesignated by Permittees shall have reasonableaccess to, and the right to copy, at theirexpense, all such books, records anddocuments, including all audit reports preparedby or furnished to the Department, together withsupporting documents in the possession of theDepartment, concerning agreements with otheragencies employed by the Department and withits independent consultants, contractors andsubcontractors, which result in costs for whichreimbursement is required by this Section.

I. With respect to the audits by Permitteesof any books, records and documents of theDepartment and its independent consultants,contractors or subcontractors under agreementswhich result in costs for which reimbursement isrequired by this Section, such audits shall beconducted by independent certified publicaccountants, designated by Permittees. Prior toconducting any such audits, such accountantsshall confer with the auditors auditing suchconsultants, contractors or subcontractors for theDepartment for the purpose of coordinating andexpediting their respective audits. Any suchaudits by such accountants shall be conductedas supplementary audits, reviewing and spotchecking the audits of the Department's auditorsfor the purpose of determining the accuracy ofcosts reflected in the billings of the Department

which are reimbursable under subsection A ofthis Section, and auditing such other matters asmay be appropriate in the circumstances. TheAuthorized Officer may designate arepresentative to observe any such audits bysuch accountants. The Authorized Officer shallhave reasonable access to, and the right tocopy, all such audit reports prepared by suchaccountants and furnished to Permittees,together with supporting documents in thepossession of the Permittees. In the event thatthe Authorized Officer believes that the scope ofany such supplementary audit is unreasonable,he shall promptly notify Permittees and suchaccountants, and such supplementary audit shallbe suspended pending consultation by theAuthorized Officer and the Permittees of theappropriate scope of audit in the circumstances.Any complaints which Permittees may have withrespect to such agreements, their performanceor the statement of the Department for thereimbursement of costs based on suchagreements shall be made only to theAuthorized Officer.

J. Permittees shall pay to the UnitedStates, through the Authorized Officer, the totalamount as shown on each statement by not laterthan the due date thereof, namely the ninetieth(90th) day following the close of the quarter towhich the statement relates; provided, however,that if any one or more of the Permittees decidesto dispute or audit any item of a statement thatshall be rendered in accordance with theprovisions of this Section or Section 18 hereof,Permittees on or before the said 90th day onwhich the statement is due and payable, shallgive the Authorized Officer written notice of eachitem that is disputed, accompanied by a detailedexplanation of their objection, or written notice ofeach item to be audited, and shall pay to theUnited States, through the Authorized Officer,those amounts for the items that are not disputedor are not to be audited. If any item of astatement is audited, Permittees shall give theAuthorized Officer prompt written notice of thecompletion of the audit of all the items of astatement being audited. On a date fixed by theAuthorized Officer, but in any event to be withinthirty (30) days after notice of a disputedstatement or after notice of the completion of theaudit, as the case may be, the Authorized Officerand Permittees shall meet to discuss, and

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attempt to resolve, all items which are disputedor which have not been resolved by the audit. Ifat that time they are unable to resolve all suchitems, Permittees may appeal any unresolveditems to the Secretary in accordance with theprovisions of subsection A of Section 26 of thisAgreement. Any items resolved as beingpayable to the United States shall be paid withinthirty (30) days after being resolved, togetherwith interest thereon up to the date of payment ata total annual percentage rate equal to thediscount rate of the Federal Reserve Bank forDistrict 12 (San Francisco) in effect on theoriginal due date of the statement, and suchinterest shall accrue and be computed from, andso as to include, the aforesaid due date. Theitems shown on any statement that are not thesubject of both: (1) a notice to the AuthorizedOfficer of a disputed item or notice of audit, and(2) a notice of appeal as provided for insubsection A of Section 26, shall be deemedconclusively to be payable to the United Statesby Permittee.

K. In addition to the right to audit quarterlystatements as provided in subsection G of thisSection, if Permittees believe that unnecessaryemployment of personnel or needlessexpenditure of funds has occurred or is likely tooccur contrary to the provisions of subsection Eof this Section, Permittees may request theapproval of the Authorized Officer for Permitteesto conduct promptly and at their own expense afull and complete audit by auditors oraccountants designated by Permittees, of thebooks, records and documents concerning thematters to be audited, at the places where suchbooks, records and documents are usuallymaintained and at reasonable times. Suchrequest shall be in writing, shall specify thematters to be audited and shall state theinformation available to Permittees upon whichthe request is based. The Authorized Officershall approve or deny such request promptly,and approval of any such request shall not beunreasonably withheld. If and to the extent thatany such audit concerns any agreements of theDepartment with independent consultants,contractors or subcontractors which haveresulted or may result in costs for whichreimbursement is required by this Section, suchaudit shall be conducted by independentcertified public accountants designated by

Permittees. The Authorized Officer maydesignate a representative to observe any auditallowed by this subsection and the AuthorizedOfficer may have access to, and the right tocopy, the audit report prepared by suchaccountants and furnished to Permittees. Anycomplaint which Permittees may have as a resultof any audit under this subsection shall be madeonly to the Authorized Officer and shall begoverned by the procedure set forth insubsection J of this Section, to the extentapplicable.

13. Damage to United StatesProperty; Repair, Replacement or

Claim for Damages

A. Subject to the provisions of subsection204 (a) (2) of the Trans-Alaska PipelineAuthorization Act, at the written demand of theAuthorized Officer, Permittees:

(1) shall repair or replace promptly, to thewritten satisfaction of the AuthorizedOfficer, all improved or tangible propertyof the United States, whether real,personal or mixed, that has beenseriously damaged or destroyed and isincluded in the demand, and

(2) shall rehabilitate (including, but notlimited to, revegetation, restocking fishor other wildlife populations andreestablishing their habitats), to thewritten satisfaction of the AuthorizedOfficer, any natural resource that shallbe seriously damaged or destroyed,

if the immediate cause of the damage ordestruction arises out of, is connected with, orresults from, the construction, operation,maintenance or termination of all or any part ofthe Pipeline System; provided, however, thatPermittees shall not be obligated to repair orreplace any property or to rehabilitate anynatural resource that was damaged ordestroyed: (a) by an act of war or (b) solely by (i)the negligence of the United States and/or (ii)the negligence or willful misconduct of Personswho are authorized to enter upon, use or occupythe damaged property or areas pursuant to anyFederal lease, permit, or other writtenauthorization that is issued for any use ofpurpose other than in connection with the

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construction, operation, maintenance ortermination of the Pipeline.

B. The repair or replacement by thePermittees of any improved or tangible propertyof the United States, as provided for insubsection A of this Section, shall operate topreclude the United States from asserting anyclaim for direct (as opposed to consequential)money damages with respect to the damage ordestruction that was so repaired or replaced.

C. Except to the extent that a claim by theUnited States for money damages against anyone or more of the Permittees shall be barred inaccordance with the provisions of subsections Aand B of this Section, Permittees shall be liableto the United States, with respect to improved ortangible property of the United States, whetherreal, personal or mixed, that is damaged ordestroyed in connection with or resulting fromactivities along or in the vicinity of the Right-of-Way in accordance with the provisions ofSection 204 of the Trans-Alaska PipelineAuthorization Act.

D. In the event that a Permittee shall beliable to the United States for any damage,destruction or loss of improved or tangibleproperty of the United States whether real,personal or mixed, the collection by the UnitedStates of money damages on account of theparticular loss, damage or destruction, shall tothe extent collected operate to preclude theUnited States from enforcing the provisions ofsubsection A of this Section with respect to suchloss, damage or destruction.

14. Indemnification of theUnited States

A. Permittees shall indemnify and holdharmless the United States, its agents andemployees, against and from any and allliabilities or damages of any nature whatsoeverwhich the United States, its agents, employees,contractors or subcontractors (at any tier)become legally obligated to pay, and which ariseout of, or are connected with, any one or more ofthe following: (1) the construction, operation,maintenance or termination of the PipelineSystem; (2) the approval (as distinguished fromthe ordering of a modification pursuant toStipulation 1.3.2.) by the United States, its

agents, employees, contractors orsubcontractors (at any tier), of any design, plan,Construction Mode, construction or researchpertaining to the Pipeline System or any partthereof ; or(3) the physical entry by any Personupon, or the use or occupancy by any Person of,any Federal Land that is the subject of any useor right which is granted or afforded toPermittees, or to their respective agents,employees, contractors or subcontractors (at anytier) in connection with the Pipeline System;provided, however, that the provisions of items(1) and (3) of this Section shall not be deemed toapply to liabilities or damages that are caused:(a) by an act of war; or (b) solely by (i) thenegligence of the United States, and/or (ii) thenegligence or willful misconduct of an agent,employee, contractor or subcontractor (at anytier) of the United States not acting within thescope of his authority or employment, and/or (iii)the negligence or willful misconduct of personswho are authorized to enter upon, use or occupythe damaged property or areas pursuant to anyFederal lease, permit, or other writtenauthorization that is issued for any use orpurpose other than in connection with theconstruction, operation, maintenance ortermination of the Pipeline System.

B. Permittees shall be notified in writing ofany claim for which indemnity under theprovisions of this Section is sought, and suchclaim shall not be compromised without thewritten consent of Permittees, which consentPermittees agree shall not be unreasonablywithheld or delayed.

C. The regulations of the Departmentrelating to indemnification of the United Statesagainst any liability for damages to life, personor property arising from the occupancy or use ofthe lands under a right-of-way (43 CFR 2801.1-5(f) (1972)) shall not be applicable to thisAgreement.

15. Guaranty

A. Upon being notified by the Secretary todo so, each Permittee shall cause to bedelivered to the Secretary a valid andunconditional guaranty of the full and timelypayment of all liabilities and obligations of thePermittee to the United States under or inconnection with this Agreement or any other

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agreement, permit or authorization to be issuedor granted to the Permittees by the Secretarythat relates in whole or in part to all or any part ofthe Pipeline System.

B. It is recognized that a proposedguarantor of a Permittee may be a corporation(or an individual stockholder thereof), apartnership (or an individual partner thereof), anassociation that is authorized and empowered tosue and be sued and to hold the title to propertyin its own name (or an individual associatethereof), a joint stock company that is authorizedand empowered to sue and be sued and to holdthe title to property in its own name (or anyindividual participant therein), or a business trust(or an individual settlor thereof), and may or maynot directly or indirectly own a legal or beneficialinterest in the Permittee whose liabilities andobligations are sought to be guaranteed. In thecase of multiple guarantors that are acceptableto the Secretary, each shall be severally liablefor only its proportionate share of any sum orpayment covered by the guaranty.

C. Each guaranty shall be satisfactory tothe Secretary in all respects including, withoutlimitation, the form and substance of theguaranty, the financial capability of a proposedguarantor, the availability of such guarantor toservice of process, the availability of the assetsof such guarantor with respect to theenforcement of judgments against the guarantor,and the number of guarantors that will benecessary to guarantee all of the liabilities andobligations which will be covered by a particularguaranty; provided, however, that the Secretaryshall not unreasonably withhold his approvalwith respect to a guaranty or guarantor.

D. The Secretary shall have the right at anytime, and from time to time, to require thesubstitution and delivery of a new form ofguaranty in the event that an outstandingguaranty is held to be invalid or unenforceable,in whole or in part, by a court of competentjurisdiction or, that the controlling law shall, bystatute or judicial decision, be so altered as toimpair, prevent or nullify the enforcement orexercise of any right or option of the UnitedStates under an outstanding guaranty; provided,however, that the outstanding guaranty (to theextent of its validity or enforceability, if any) shallcontinue in full force and effect with respect to

any claim, suit, accrued liability or defensethereunder that exists at the time of substitution;provided further, that the new form of guaranty,in each such case, shall be required as to allPermittees that at the time of substitution havedelivered, or are required to deliver, a guaranty.

E. Each guaranty shall be accompanied bysuch certificates and opinions of legal counselas the Secretary may require to establish itsvalidity. The guaranty shall include anappointment of an agent for service of processthat is satisfactory to the Secretary.

16. Laws and Regulations

A. Permittees, and each of them, shallcomply with all applicable Federal laws andregulations, existing or hereafter enacted orpromulgated.

B. In any event, Permittees, and each ofthem, shall comply with: (1) all regulationshereafter promulgated to implement the Trans-Alaska Pipeline Authorization Act, and(2) allapplicable regulations hereafter promulgated toimplement Section 28 of the Mineral leasing Actof 1920, as amended.

17. No Right of Set Off

With respect to any sum now or hereafterowing, or claimed to be owing, to the UnitedStates and that arises out of or is connected inany way with the construction, operation,maintenance or termination of all or any part ofthe Pipeline System, Permittees, and each ofthem, shall not set off against, or otherwisededuct from, any such sum:

(1) Any claim or judgment for money of anyone or more of the Permittees againstthe United States not arising out of theconstruction, operation, maintenance ortermination of all or any part of thePipeline System;

(2) Any claim or judgment for money of anyone or more of the Permittees againstthe United States that arises out of theconstruction, operation, maintenance ortermination of all or any part of thePipeline System, if the sum now orhereafter owing, or claimed to be owing,

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to the United States is or shall be for anysum or charge required to be paid to theUnited States pursuant to Section 8,Section 12 or Section 18 hereof; or

(3) Any claim or judgment for money of anyone or more of the Permittees againstthe United States their arises out of, orpursuant to, any statute administered byany department or agency of the UnitedStates other than the Department.

18. Right of United States to Perform

A. If, after thirty (30) days, or in anemergency such shorter period as shall not beunreasonable, following the making of a demandtherefor by the Authorized Officer, in the mannerthat is provided in Stipulation 1.6 for givingwritten notices, Permittees, or their respectiveagents, employees, contractors orsubcontractors (at any tier), shall fail or refuse toperform any of the actions required by theprovisions listed in subsection B of this Section,the United States shall have the right, but not theobligation, to perform any or all of such actionsat the sole expense of Permittees. Prior to thedelivery of any such demand, the AuthorizedOffice shall confer with Permittees, if he deems itpracticable to do so, regarding the requiredaction or actions that are included in thedemand. The Authorized Officer, following theprocedure outlined in subsection F of Section 12hereof, shall submit to Permittees a statement ofthe expenses incurred by the United Statesduring the preceding quarter in the performanceby the United States of any required action and,in the absence of a dispute, the amounts shownto be due on each such statement shall be paidby Permittees in accordance with the provisionsof the said last mentioned subsection. If any oneor more of the Permittees shall dispute theamount of any item in any statement that shallbe rendered in accordance with the provisions ofthis Section, the procedures outlined insubsection J of Section 12 shall apply with equalforce and effect to any such dispute. Permitteesmay dispute whether the work involved an actionrequired by a provision listed in subsection B ofthis Section, whether Permittees' failure orrefusal to perform any such action was justified,as well as the reasonableness of thespecifications for, and the cost of, such work.

B. Required Action (In General) andReference:*

Survey, map and mark the Right-of-Way-Sec. 6.

Repair, replace, rehabilitate property andnatural resources-Sec. 13.

Discharge liens-Sec. 19.Abate any condition causing or threatening

to cause a hazard, harm or damage-Sec. 24.

Provide emergency aid-Sec. 30.Provide an archeologist to perform certain

duties-Stip. 1.9.Remove improvements and equipment and

restore land-Stip. 1.10.1.Put areas "to bed�-Stip. 1.10.2.Protect certain improvements; remove

obstructions; repair damage to publicutilities and improvements-Stip.-1.11.

Regulate public access-Stip. 1.12.1.Provide alternative routes for roads and

trails-Stip. 1.12.2.Provide public crossings-Stip. 1.12.3.Screen, filter, suppress electronic devices-

Stip. 1.13.1.Post the Right-of-Way against hunting, etc.-

Stip. 1.14.1.Restore survey monuments, etc.-

Stip. 1.16.2.Take measures to protect health and safety;

abate hazards-Stip. 1.20.Provide for environmental briefings-

Stip. 2.1.1.Remove waste-Stip. 2.2.6.2.Stabilize disturbed areas-Stip. 2.4.2-2.Remove temporary fill ramps-Stip. 2.4.3.2.Seed and plant disturbed areas-Stip. 2.4.4.1.Dispose of excavated material-Stip. 2.4.5.Provide for uninterrupted movement and

safe passage of fish-Stip. 2.5.1.1.Screen pump intakes-Stip. 2.5.1.2.Plug, stabilize abandoned water diversion

structures-Stip. 2.5.1.3.Construct levees, etc.-Stip. 2.5.1.4.Construct new channels-Stip. 2.5.2.2.Protect Fish Spawning Beds from sediment;

construct settling basins-Stip. 2.5.2.3.Repair damage to Fish Spawning Beds-

Stip. 2.5.2.4.

* �Sec.� Refers to Sections of this Agreement.

�Stip.� Refers to the Stipulations, attached asExhibit D hereto.

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Assure big game passage-Stip. 2.5.4.1.Remove certain debris-Stip. 2.7.2.5.Dispose of slash (where "otherwise

directed.")-Stip. 2.7.2.8.Take certain mitigation measures-Stip. 2.8.1.Restore disturbed areas-Stip. 2.12.1.Stabilize slopes-Stip. 2.12.2.Dispose of certain materials-Stip. 2.12.3,

Stip. 2.12.4.Remove equipment and supplies-Stip.

2.12.5.Clean up, repair, if Oil or other pollutant is

discharged-Stip. 2.14.4.Inspect welds-Stip. 3.2.2.3.Inspect Pipeline System construction-

Stip. 3.2.2.4.Perform seismic monitoring-Stip. 3.4.2.3.Construct stilling basins; stabilize pool

sides-Stip. 3.6.2.1.Provide Oil spill containment structures-

Stip. 3.11.1, Stip. 3.11.2.

19. Liens

A. Each Permittee shall, with reasonablediligence, discharge any lien against FederalLands that results from any failure or refusal onits part to pay or satisfy any judgment orobligation that arises out of or is connected inany way with the construction, operation,maintenance or termination of all or any part ofthe Pipeline System.

B. However, Permittees shall prevent theforeclosure of any lien against any title, right, orinterest of the United States in said lands.

C. The foregoing provisions of this Sectionshall not be construed to constitute the consentof the United States to the creation of any lienagainst Federal Lands or to be in derogation ofany prohibition or limitation with respect to suchliens that may now or hereafter exist.

20. Insolvency

If at any time there shall be filed by oragainst any Permittee, or any guarantorfurnishing a guaranty in accordance with theprovisions of Section 15 hereof, in any court ofcompetent jurisdiction, a petition in bankruptcyor insolvency or for reorganization or for theappointment of a receiver or trustee of all or aportion of the Permittee�s or such guarantor's

property, or if any Permittee, or any suchguarantor, makes an assignment for the benefitof creditors or takes advantage of any insolvencyact, and, in the case of an involuntaryproceeding, within sixty (60) days after theinitiation of the proceeding the Permittee or suchguarantor fails to secure a discontinuance of theproceeding, the Secretary may, if the Secretaryso elects, at any time thereafter, declare such tobe a breach of this Agreement by the Permitteeor, in cases involving a guarantor, the Permitteefor which the guaranty was furnished.

21. Breach; Extent of Liability ofPermittees

The liabilities and obligations of eachPermittee under this Agreement are joint andseveral except that the liabilities and obligationsof each Permittee are several under thefollowing Sections: 2.D (Purpose of Grant;Limitation of Use to Permittees), 3(Transportation of Oil), 8 (Use Charge for Right-of-Way), 12 (Reimbursement of DepartmentExpenses), 13.C (Damage to United StatesProperty; Repair, Replacement or Claim forDamages), 14 (Indemnification of United States),15 (Guaranty), 18 (Right of the United States toPerform), 19.A (Liens), 20 (Insolvency), 22(Transfer), 32 (Release of Right-of-Way), 33.Band 33.C, to the extent that performance may berequired by less than all of the Permittees(Agreements Among Permittees), 34. (Access toDocuments), 41 (Authority to Enter Agreement),Stipulation 1.4 (Common Agent), and Stipulation1.10.1 (Completion of Use); provided, however,that as to any obligation to pay money to theUnited States, each such Permittee shall not beliable for any greater portion thereof than anamount which is equal to the product of the totalobligation or liability when multiplied by afraction, the numerator thereof being theindividual Permittee's interest in the Right-of-Way at the time of the breach (such interestbeing expressed as a percentage for purposes ofthe numerator), and the denominator thereofbeing the aggregate of all of the interests in theRight-of-Way that were held by all of thePermittees at the time the obligation becomesdue and payable (the aggregate of such interestbeing expressed as a percentage for purposes ofthe denominator).

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22. Transfer

A. Permittees, and each of them, shall not,without obtaining the prior written consent of theSecretary, Transfer in whole or in part any right,title or interest in this Agreement or the Right-of-way. Any such Transfer other than with to anInvoluntary Passage of Title, without in eachinstance obtaining the prior written consentthereto of the Secretary, shall be absolutely void,and, at the option of the Secretary, shall bedeemed to be a breach of this Agreement byeach Permittee so violating this Agreement.

B. Any Involuntary Passage of Title withrespect to any right, title or interest in thisAgreement or the Right-of-Way that shall beattempted or effected without in each instanceobtaining the prior written consent thereto of theSecretary shall, to the extent permitted by law,be voidable at the option of the Secretary, and,in addition, at the option of the Secretary, shallbe deemed to be a breach of this Agreement bythe affected Permittee; provided, however, thatnothing in this subsection shall be deemed toprohibit, or to limit in any way, the exercise ofany right or option of the United States underSection 20 of this Agreement.

C. With respect to any Transfer that shallrelate to this Agreement or the Right-of-Way, theTransferor, the Transferee and the guarantor orguarantors, if any, of the Transferee shall applyfor the Secretary's written consent to theTransfer by filing with the Secretary alldocuments or other information that may berequired by law or regulation, this Agreement orany other agreement, permit, or authorization ofthe United States relating to the Pipeline Systemor any part thereof and, upon request from theSecretary, such other documents andinformation as may be relevant to the Secretary'sdetermination.

D. Before the Secretary acts in connectionwith an application for his consent with respectto the Transfer of an interest in the Right-of-Way,the Transferee shall demonstrate, to thesatisfaction of the Secretary, that the Transfereeis capable of performing all of the liabilities andobligations of the Transferor relating to theinterest to be transferred. In considering anapplication for such consent, the Secretary shallmake a determination, in accordance with

Section 28(j) of the Mineral Leasing Act of 1920,as amended, concerning: (1) the technicalcapability of the Transferee, and (2) the financialcapability of the Transferee, or of the Transfereetogether with, if any, its proposed guarantor orguarantors as approved by the Secretary, toperform all of the liabilities and obligations of theTransferor relating to the interest to betransferred.

E. In connection with any Transfer, theSecretary may request the right to audit and/orinspect, in whole or in part, the pertinent books,records, accounts, contracts, commitments, andproperty of the Transferee and of the proposedguarantor or guarantors, if any, of theTransferee, at the sole expense of theTransferor, which expense shall be paid to theUnited States upon completion of the inspectionand/or audit and before the Secretary acts inconnection with the application for his consent tothe Transfer. If any such request shall berefused such refusal shall be deemed to be asufficient reason for the Secretary to withhold hisconsent to the pertinent Transfer. TheTransferee and its guarantor or guarantors, ifany, shall consent in writing to the provisions ofthis subsection when applying for the consent ofthe Secretary.

F. The Secretary, shall not unreasonablywithhold his consent to any Transfer hereunder,but may withhold or revoke his consent to anyTransfer if:

(1) At the time of, or before, theconsummation of the Transfer, thereshall have occurred any breach, by theTransferor or any predecessor of theTransferor, of this Agreement or of anyother agreement, permit, orauthorization relating to the PipelineSystem that the United States may makewith, issue to, or grant to the Transferor,and that was not cured to thesatisfaction of the United States beforethe consummation of the Transfer, or

(2) With respect to Transfers other thanthose referred to in subsection H of thisSection, the Transferee, or theTransferee together with, if any, itsguarantor or guarantors as approved bythe Secretary: (a) is not, or are not,

APPENDIX F

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capable, in the judgment of theSecretary, of performing all of theliabilities and obligations of theTransferor relating to the right, title orinterest to be transferred, or (b) shallrefuse to allow an audit and/orinspection as provided for insubsection E of this Section; or

(3) Applicable laws and regulations in effectat the time of a Transfer shall not havebeen complied with by the parties to theTransfer.

G. A Permittee seeking to be divested inwhole or in part of its right, title, and interest inand to the Right-of-Way and this Agreement inconnection with a Transfer shall be releasedfrom its liabilities and obligations (accrued,contingent, or otherwise) to the United Statesunder this Agreement to the extent and limit thatthe Transferee assumes unconditionally theperformance and observance of each suchliability and obligation, provided:

(1) All of the provisions of this Agreementwith respect to the approval ordisapproval of the Transfer have beenfully complied with to the satisfaction ofthe Secretary;

(2) The Secretary has consented in writingto the Transfer; and

(3) Thereafter the Transfer and theattendant assumption agreement, if any,are in fact duly consummated on thebasis of the documents previouslypresented to the Secretary for hisreview, and the Secretary is so notifiedin writing by the parties to the Transfer.

H. The Secretary shall consent to theTransfer of an interest in the Right-of-Waybetween:

(1) Any of the Original Permittees, theirAffiliates or any of them, or

(2) One or more of the Original Permittees,their Affiliates or any of them, and acorporate Transferee, all of theoutstanding capital stock of whichTransferee at the time of the Transfer is

owned by one or more of the OriginalPermittees or their Affiliates; or

(3) One or more of the Original Permittees,their Affiliates or any of them, and apartnership consisting of two (2) or moreof the Original Permittees or theirAffiliates;

provided, that the Transferor or Transferee arenot in breach of this Agreement; provided further,that all applicable laws and regulations in effectat the time of Transfer are complied with;provided further, that the application for any suchTransfer be filed with the Secretary within eight(8) years of the Effective Date hereof or priorcompletion of construction of the Pipeline at itsmaximum design capacity (i.e. approximatelytwo million (2,000,000) barrels per day)whichever shall first occur; and provided further,that no substantial reduction in the financialworth of the Transferee (or its Parent), or of theTransferee (or its Parent) together with itsguarantors, if any, has occurred since the datethe Transferee (or its Parent) acquired itsoriginal interest in the Right-of-Way.

23. Port Valdez Terminal Facility

A. The provisions of this Section shallapply to the construction and operation of theterminal facility of the Pipeline System located atPort Valdez, Alaska.

B. Permittees shall maintain and operate awaste-water treatment facility in conjunction withthe terminal facility at Port Valdez. All oily water(including, but not limited to, discharge from fueltanks, cargo tanks, ballast tanks, and bilges)discharged from any tanker or other seagoing,bulk Oil carrier (hereinafter referred to as a"Vessel") loading at or from the terminal facilityshall be received and treated by said wastewatertreatment facility. Water discharged from thewaste-water treatment facility shall not containmore than 10 parts of oil per million parts ofwater, on a weekly (seven (7) day) average.

C. At reasonable intervals, but at least oncein every five (5) year period, the AuthorizedOfficer and Permittees, at the request of either,shall meet to review and consider in depth: (1)the operation of the wastewater treatmentfacility; (2) such advances and improvements in

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water pollution control and waste-watertreatment, technology and equipment, as theyrelate the terminal facility, as have taken place;and (3) the feasibility of improving theperformance of the facility through installation ofnew or additional equipment, or modification ofexisting-equipment. Consideration of suchfeasibility shall include consideration of thedegree of technological advances that haveoccurred, costs and economic feasibility, thetypes of equipment commercially available, andthe benefits that would be derived from theinstallation of new or additional equipment or themodification of existing equipment.

D. Permittees, and their respective agents,employees, contractors and subcontractors (atany tier) shall not release, or suffer be released,from the terminal facility any Oil be loaded onany Vessel unless the provisions of subsectionsE and F of this Section have, in each case, beenfully complied with.

E. Prior to loading Oil on any Vessel,Permittees shall require the master thereof toprovide Permittees with a legible copy, certifiedunder oath by the master as being true andcorrect, of:

(1) in the case of Vessels of United Statesregistry, that part of the oil record bookof such Vessel that pertains to thevoyage of the Vessel the terminal facilityfrom its last Oil discharge port;

(2) in the case of Vessels of foreign registrythat may now or hereafter be required tomaintain an oil record book, or similarrecords, that part of the oil record book,or said records, that pertains thevoyage of the Vessel to the terminalfacility from its last Oil discharge port;and

(3) in the case of any Vessel of foreignregistry that is not required the maintainan oil record book, or similar records,Permittees shall require the masterthereof to provide Permittees with anaffidavit, duly sworn to and signed by themaster, stating any and all facts bearingupon any discharge of Oil or oily waterfrom the Vessel during its voyage to the

terminal facility from its last Oildischarge port.

F. If the said record book entries oraffidavit, as provided by the master, disclose:

(1) that the Vessel has discharged any Oilor oily water from its fuel tanks, cargotanks, bilge, or otherwise, and

(2) that such discharge was not necessaryfor the safety of the Vessel or its crew,

Permittees shall promptly notify the AuthorizedOfficer of the pertinent facts and shall not loadthe Vessel or suffer the Vessel to be loaded,unless at the time of such discharge:

(a) The United States Coast Guard or otheragency of the United States haspromulgated and implementedregulations under one or more treaties,conventions, or statutes that aredesigned to deter Vessels subject tosuch treaties, conventions or statutesfrom discharging any Oil or oily water atsea and that apply to, and can beenforced by the United States CoastGuard or such other agency of theUnited States against, the offendingVessel; or

(b) In the absence of the aforesaidregulations, or the inapplicability thereofto the offending Vessel, there shall be ineffect port rules, approved in writing bythe Authorized Officer for the purposesof this subsection F, for the port ofValdez or, as the case may be, theterminal facility, (which rules mayprovide for a demurrage charge againstoffending vessels) that are designed todeter any Vessel using the terminalfacility from discharging Oil or oily waterat sea and that apply to, and can beenforced against, the offending vessel;or

(c) If neither subsection F (a) or F (b) abovein this Section shall be applicable,Permittees may proceed subject toapplicable laws and regulations, to loadthe Vessel at the terminal facility;provided, however, that during its next

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return voyage the terminal facility, one ofeither of the following alternatives mustbe complied with before the Vessel canbe loaded:

(i) (AA) The Vessel shall, prior toloading, remain for ten (10)consecutive hours (the"Standdown Period") in anarea designated by theAuthorized Officer, not nearerthan fifty (50) nautical miles orfarther than one hundred (100)nautical miles from the port ofValdez;

(BB) The Vessel's master shallenter in the ship's log the timeand position of the Vessel atthe commencement andtermination of the StanddownPeriod, as well as the hourlypositions of the Vessel duringsaid period;

(CC) The Vessel's position at thepoint of departure, uponcompletion of the StanddownPeriod, shall not be greaterthan five (5) nautical milesfrom the Vessels position atthe commencement of suchperiod; and

(DD) Prior to loading the Vessel,Permittees shall receive fromthe master of the Vessel alegible copy, certified underoath by the master as beingtrue and correct, of theaforementioned entries in theship's log; or

(ii) (AA) The Vessel shall proceed toValdez at a reduced rate ofspeed so that the voyage toValdez (from its last port of callbefore such voyage) requiresat least ten (10) hoursadditional to the period of timethe voyage would otherwisehave taken; and

(BB) Prior to loading the Vessel,Permittees shall receive fromthe master of the Vessel alegible copy, certified as beingtrue and correct, of the entriesin the ship's log whichdemonstrate compliance withthe aforementioned return-voyage requirements.

Notwithstanding the foregoing provisions ofsubsections F(c)(i) and F(c)(ii), the AuthorizedOfficer may temporarily waive compliance withthe return-voyage requirements (on such termsas the Authorized Officer may prescribe) if, fromthe ship's log and corroborative evidence, it isclearly demonstrated that compliance wouldhave seriously jeopardized the safety of the shipor crew.

G. If a Vessel shall have been loaded at theterminal facility without being subjected to any ofthe alternatives that are prescribed in subsectionF of this Section, and it should later bedetermined that the portion of the oil recordbook, a copy of which was furnished toPermittees prior to such loading, or affidavit, asthe case may be, contained any false ormisleading statement or did not contain arequired entry or statement, and if the entry orstatement had been properly made the Vesselwould have been subject the aforesaidalternatives, then the Vessel shall be subject tothe provisions of subsections E and F on itsreturn voyage to the terminal facility nextfollowing the date on which the AuthorizedOfficer notifies Permittees and the owner and/or,if any, the charterer of such Vessel of theaforementioned determination.

H. Permittees shall:

(1) Publish the restrictions placed on theloading of Vessels at the terminal facilityunder this Section in the port manual forthe port of Valdez or, as the case maybe, the terminal facility and, if legallypermissible, in the tariff or tariffspertaining of the transportation of Oilthrough the Pipeline; and

(2) Give the public such other notice of saidrestrictions as Permittees or theAuthorized Officer may, from time to

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time, consider to be necessary orappropriate.

I. Permittees shall maintain books andrecords in connection with the operation of thewaste-water treatment facility. Said books andrecords shall at least show, for each Vesseldischarging into said facility, the name, tonnage(D.W.T.) and such other information as may beappropriate to identify the Vessel, the date ofeach discharge, the amount of ballast waterdischarged on each occasion, the amount ofother oily water discharged on each occasion,and the amount of Oil that was loaded on eachoccasion from the terminal facility.

J. Permittees shall retain, for anappropriate period, as prescribed by theAuthorized Officer, all documents furnished toPermittees pursuant to subsections E and F ofthis Section and the books and records specifiedin subsection I of this Section; and theAuthorized Officer shall have access thereto atall reasonable times for the purpose inspectionand copying.

K. Permittees shall comply with all Federal,State and local laws and regulations existing orhereafter enacted or promulgated affecting inany manner the construction and operation ofthe terminal facility. If any such law or regulationgoverns specifically any particular requirementor standard that is prescribed in this Section.Permittees shall comply with the requirement orstandard established by such law or regulationand, so long as compliance is required,Permittees shall be relieved of any obligation tocomply with the particular requirement orstandard of this Section that is governed by suchlaw or regulation.

24. Duty of Permittees to Abate

A. Permittees promptly shall abate, eithercompletely or, as the case may be, ascompletely as possible using their best efforts,any physical or mechanical procedure, activity,event or condition, existing or occurring at anytime: (1) that is susceptible to abatement byPermittees, (2) which arises out of, or couldaffect adversely, the construction, operation,maintenance or termination of all or any part ofthe Pipeline System, and (3) that causes orthreatens to cause: (a) a hazard to the safety of

workers or to public health or safety (includingbut not limited to personal injury or loss of lifewith respect to any Person or Persons), or(b) serious and irreparable harm or damage tothe environment (including but not limited toareas of vegetation or timber, fish or otherwildlife populations, or their habitats, or anyother natural resource).

B. Permittees shall cause their respectiveagents, employees, contractors andsubcontractors (at any tier) to observe andcomply with the foregoing provisions of thisSection.

25. Temporary Suspension Orders ofAuthorized Officer

A. The Authorized Officer may at any timeorder the temporary suspension of any or allconstruction, operation, maintenance ortermination activities of Permittees, their agents,employees, contractors or subcontractors (at anytier) in connection with the Pipeline System,including but not limited to the transportation ofOil, if in the judgment of the Authorized Officer:

(1) An immediate temporary suspension ofsuch activities is necessary protect: (a)public health or safety (including, but notlimited to, personal injury or loss of lifewith respect any Person or Persons);or(b) the environment from immediate,serious, substantial and irreparableharm or damage (including, but limitedto, harm or damage to areas ofvegetation or timber, fish or other wildlifepopulations, or their habitats, or anyother natural resource); or

(2) Permittees, their respective agents,employees, contractors orsubcontractors (at any tier) are failing orrefusing, or have failed or refused, tocomply with or observe: (a) anyprovision of this Agreement necessaryto protect public health, safety or theenvironment; or (b) any order of theAuthorized Officer implementing anysuch provision of this Agreement or ofany other agreement, permit orauthorization that shall have been dulyapproved, issued or granted by the

APPENDIX F

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Secretary in connection with all or anypart of the Pipeline System.

B. The following shall be applicable to anytemporary suspension order that may be issuedin accordance with the provisions of subsectionA of this Section, if the order would have theeffect of suspending (1) operation of the entirePipeline, (2) transportation of Oil through thePipeline, (3) operation of the entire Valdezterminal facility, or (4) construction of an entireConstruction Subdivision:

(a) If the order is issued in accordance withsubsection A (l) of this Section, theAuthorized Officer shall transmit a copyof the order, and a preliminary reportwith respect to the order, to theSecretary within six (6) hours after theorder has been issued and, thereafter,the Authorized Officer's report and theorder will be reviewed promptly by theSecretary; provided, however, thatnothing therein shall require theSecretary to take any action followingsuch review; or

(b) If the order is to be issued in accordancewith subsection A (2) of this Section, theAuthorized Officer shall not issue theorder unless and until the Secretarygives the Authorized Officer theSecretary's prior written approval withrespect to the order.

C. The Authorized Officer shall givePermittees prior notice of the temporarysuspension order as he deems practicable. Ifcircumstances permit, the Authorized Officershall consult with Permittees, prior to issuing theorder, discuss appropriate measures(1) forthwith abate or avoid the harm orthreatened harm that is the reason for theissuance of the order, or (2) effect compliancewith the provision or order, whichever isapplicable.

D. After a temporary suspension order hasbeen given by the Authorized Officer, Permitteesshall promptly comply with all of the provisionsof the order and shall not resume any activitysuspended or curtailed thereby except asprovided in this Agreement or pursuant courtorder.

E. Any temporary suspension order which,in an emergency, is given orally shall beconfirmed in writing, as provided for inStipulation 1.6.2. Each written order or writtenconfirmation of an order shall set forth thereasons for the suspension. Each temporarysuspension order shall be limited, insofar as ispracticable, the particular area or activity that isor may be affected by the activities or conditionsthat are the basis of the order. Each order shallbe effective as of the date and time given, unlessit specifies otherwise. Each order shall remainin full force and effect until modified or revokedin writing by the Authorized Officer or theSecretary.

F. Resumption of any suspended activityshall be promptly authorized by the AuthorizedOfficer in writing when he is satisfied that (1) theharm or threatened harm has been abated orremedied, or (2) Permittees have effected, or areready, willing and able effect compliance withthe provision or order, whichever is applicable.

G. Any temporary suspension order that isgiven or issued in accordance with this Sectionshall be subject the provisions ofStipulation 1.5.1.

26. Appeal Procedure

A. Appeals from Temporary Suspension Ordersof Authorized Officer; Appeals from Denialsof Resumption of Suspended Activities

(1) Permittees may appeal directly to theSecretary: (a) any temporary suspension orderissued by the Authorized Officer pursuant toSection 25 of this Agreement; and (b) any denialby the Authorized Officer of a request forresumption of activities suspended pursuant tosuch a temporary suspension order. If a right ofappeal is to be preserved, Permittees shall file anotice of appeal with the Secretary within fifteen(15) days from the effective date of the order ordenial being appealed. The notice shall set forthwith particularity the order or denial beingappealed. To perfect an appeal, Permittees shallfile with the Secretary within thirty (30) days fromthe effective date of the order or denial beingappealed a statement of the facts of the matterand a statement of the applicable law,supplemented by such documentation andarguments on the facts and the law as

APPENDIX F

20

Permittees may wish to present to justifymodification or reversal of the order or denial.All statements of fact shall be under oath.

(2) Except as provided hereinafter in thisSection, the Secretary shall decide the appealwithin thirty (30) days from the date Permittees'appeal is perfected. If the Secretary does notrender a decision within that time, the appealshall be considered to have been denied by theSecretary, and such denial shall constitute thefinal administrative decision of the Department.

(3) Except for any decision that may bemade by the Secretary after his review asprovided for in subsection b (a) of Section 25hereof, any decisions of the Secretary, withrespect any appeal within the Department as anymatter arising out of this Agreement, shallconstitute the final administrative decision of theDepartment.

B. Expedited Appeals

(1) Permittees shall be entitled to anexpedited appeal the Secretary from anytemporary suspension order, or order denyingresumption of suspended activities (except anyrefusal to issue a Notice to Proceed or theissuance of a Notice to Proceed that may not besubstantially in accord with the applicationtherefor), issued by the Authorized Officer andthat suspends, or denies resumption of, thefollowing: (a) operation of the entire Pipeline;(b) transportation of Oil through the Pipeline;(c) operation of the entire Valdez terminalfacility; or (d) construction of an entireConstruction Subdivision.

(2) Permittees may occasionally, from timeto time, during construction of the PipelineSystem, designate an order not covered bysubsection b (1) of this Section but which thePermittees deem critical and which theSecretary shall consider as an expedited appeal.Such designation shall be made in the notice ofappeal and shall be supported by factualinformation, under oath, to confirm that theaffected activity is one of critical importance.

(3) The Secretary shall render a decision soas dispose of the expedited appeal within theshortest possible time and in all events withinseven (7) days of the date of filing of the

documents required to perfect an appeal. If theSecretary does not render a decision within suchtime, the appeal may be deemed by Permitteesto have been denied by the Secretary, and suchdenial shall constitute the final administrativedecision of the Department.

C. Appeals with Respect to Notices to Proceed

(1) Permittees may appeal to the Secretaryif, with respect to a particular application for aNotice to Proceed: (a) the Authorized Officer hasrefused to issue the Notice to Proceed within thetime prescribed pursuant to Stipulation 1.7.4; or(b) the Authorized Officer has issued a Notice toProceed not substantially in accord with theapplication therefor. If the Authorized Officerhas not acted within the prescribed time to eitherissue or deny the issuance of the Notice toProceed, such failure to act shall be deemed tobe a refusal by the Authorized Officer to issuethe Notice to Proceed.

(2) The ground or grounds for such anappeal shall be one or more of the following:(a) The Authorized Officer has construed theapplicable Stipulations erroneously; or (b) TheAuthorized Officer has imposed arbitrary andcapricious requirements to enforce theStipulations; or (c) Permittees have made a bonafide effort to meet the requirements of theAuthorized Officer, but are unable to comply; or(d) By failing to act upon the requested Notice toProceed, within the prescribed time, theAuthorized Officer has been unreasonable.

(3) Each appeal under this subsection shallbe subject to the appeal procedure set forth insubsection A of this Section.

27. Requests to Resume; Appeals

A. If by a temporary suspension orderissued pursuant to Section 25 of this Agreement,the Authorized Officer has ordered thesuspension of an activity of Permittees,Permittees may at any time thereafter file withthe Authorized Officer a request for permissionto resume that activity on the ground that thereason for the suspension no longer exists. Therequest shall contain a statement, under oath, ofthe facts which in Permittees' view support thepropriety of resumption.

APPENDIX F

21

B. The Authorized Officer shall render adecision, either granting or denying the request,within five (5) days of the date that the requestwas filed with him. If the Authorized Officer doesnot render a decision within that time, therequest shall be considered denied andPermittee may appeal the denial to the Secretaryin accordance with the provisions of Section 26of this Agreement.

C. If, at the time the request to resume isfiled with the Authorized Officer, the AuthorizedOfficer's order suspending the activity is pendingbefore the Secretary pursuant to a perfectedappeal, the Authorized Officer shall nonethelessproceed to act upon the request. If theAuthorized Officer grants the request that actionshall be determinative of both the request andthe pending appeal.

28. Nondiscrimination and EqualEmployment Opportunity¥

A. Permittees shall assure that no personshall on the grounds of race, creed, color,national origin or sex be excluded from receivingor participating in any activity, including allaspects of employment and contracting,conducted under any permit, right-of-way, publicland order, or other Federal authorizationgranted or issued under the Trans-AlaskaPipeline Authorization Act. Permittees shallcomply with all regulations that shall bepromulgated by the Secretary to implement thisprovision.

B. Permittees agree that, during the periodof construction of the Pipeline System and for solong as the Pipeline System, or any portionthereof, shall be in operation, or for so long asthis Agreement shall be in effect, whichever isthe longer:

(1) The recipient hereby agrees that it willnot, directly or through contractual orother arrangements, on the grounds ofrace, creed, color, national origin, orsex, discriminate against any individualor establishment in offering or providingcontracts, employment, services,

¥ Modification of this section adopted pursuant

to letter of the Secretary of the Interior datedSeptember 22, 1977.

financial aids, or other benefits.Recipient will take affirmative action toutilize minority business enterprises inthe performance of contracts awardedby recipient, to assure that applicants foremployment are employed and thatemployees are treated duringemployment, and that individuals areoffered and provided services, financialaids, and other benefits without regardto their race, creed, color, nationalorigin, or sex. Recipient agrees to postin conspicuous places available tocontractors, employees, and otherinterested individuals, notices which setforth these equal opportunity terms andto notify interested individuals, such asbidders, purchasers, and labor unions orrepresentatives of workers with whom ithas collective bargaining agreements ofrecipient's obligations under section 403of Public Law 93-153.

(2) The recipient will comply with all rules,regulations, and orders of theDepartment of the Interior whichimplement section 403 of PublicLaw 93-153.

(3) The recipient will furnish all informationand reports required by or pursuant torules, regulations, and ordersimplementing section 403 of Public Law93-153 and permit access to its books,records, and accounts by the Secretaryof the Interior, the DepartmentCompliance Officer, or other designee ofthe Secretary, for purposes ofinvestigation to ascertain compliancewith rules, regulations, and orders of theDepartment of the Interior whichimplement section 403 of PublicLaw 93-153.

(4) The recipient recognizes and agrees thatits obligation for compliance withsection 403 of Public Law 93-153 andimplementing rules, regulations, andorders extends not only to directactivities, but also to require thatcontractors, subcontractors, suppliers,and lessees, comply with section 403and implementing rules, regulations andorders. To that end the recipient agrees

APPENDIX F

22

that with regard to all contracts over$10,000 and all contracts of indefinitequantity (unless there is reason tobelieve that the amount to be ordered inany year under the contract will notexceed $10,000) to:

(a) Obtain as part of its contractualarrangements with such parties, asa minimum form of assurance anagreement in writing, that:

(i) The contractor hereby agrees that itwill not, directly or throughcontractual or other arrangements,on the grounds of race, creed, color,national origin, or sex, discriminateagainst any individual orestablishment in offering orproviding contracts, employment,services, financial aids, or otherbenefits. Contractor will takeaffirmative action to utilize minoritybusiness enterprises in theperformance of subcontracts whichis awards, and to assure thatapplicants are employed and thatemployees are treated duringemployment, and that individualsare offered and provided services,financial aids, and other benefitswithout regard to their race, creed,color, national origin, or sex.Contractor agrees to post inconspicuous places available tocontractors, employees, and otherinterested individuals notices whichset forth these equal opportunityterms and to notify interestedindividuals, such as bidders,purchasers, and labor unions orrepresentatives of workers withwhom it has collective bargainingagreements of contractor'sobligations under section 403 ofPublic Law 93-153.

(ii) The contractor will comply with allrules, regulations, and orders of theDepartment of the Interior whichimplement section 403 of PublicLaw 93-153.

(iii) The contractor will furnish allinformation and reports required byor pursuant to rules, regulations,and orders implementing section403 of Public Law 93-153 and permitaccess to its books, records, andaccounts by the Secretary of theInterior, the Department ComplianceOfficer, or other designee of theSecretary, for purposes ofinvestigation to ascertaincompliance with rules, regulations,and orders of the Department of theInterior which implement section 403of Public Law 93-153.

(iv) Contractor's noncompliance with thenondiscrimination clauses of thiscontract or with any of said rules,regulations, and orders shallconstitute a breach of its contractualarrangements whereby saidarrangements may be cancelled,terminated, or suspended, or maybe subject to enforcement otherwiseby appropriate legal proceedings.

(v) Contractor will obtain the provisionsof paragraph (4)(a) (i) through (v) ofthis section in all subcontracts over$10,000 and all subcontracts ofindefinite quantity (unless there isreason to believe that the amount tobe ordered in any year under thecontract will not exceed $10,000).

(b) Recipient will make every good faitheffort to secure the compliance andwill assist and cooperate activelywith the Department ComplianceOfficer and the Secretary or hisdesignee in obtaining and enforcingthe compliance of said contractingparties with the requirements ofsection 403 and implementing rules,regulations, and orders, and withtheir respective contractualarrangements; and will take suchaction with respect to any contract orpurchase order that the Secretary ofthe Interior, the DepartmentCompliance Officer, or otherdesignee of the Secretary may directas a means of enforcing such

APPENDIX F

23

provisions: Provided, however, Thatin the event the recipient becomesinvolved in litigation with anoncomplying party, it may requestthe Department of the Interior toenter into such litigation to protectthe interests of the United States inthe enforcement of theseobligations, and

(c) Recipient will obtain and furnish tothe Department Compliance Officersuch information as he may requirefor the supervision or securing ofsuch compliance.

(5) In the event of the recipient'snoncompliance with the equalopportunity terms, compliance may beeffected by the suspension ortermination or refusal to grant or tocontinue providing the Federalauthorization in accordance withprocedures authorized by section 403 ofPublic Law 93-153, and set forth inimplementing rules, regulations, ororders, or by any other meansauthorized by law.

Permittees further agree that they will bebound by the equal opportunity clause(i.e., subsections (1) through (5) of thissubsection B) with respect to their ownemployment practices when they participate infederally assisted construction work.

29. Training of Alaska Natives

A. Permittees shall enter into anAgreement with the Secretary regardingrecruitment, testing, training, placement,employment, and job counselling of AlaskaNatives.

B. During construction and operation of thePipeline System, Permittees shall conduct a pre-employment and on-the-job training program forAlaska Natives designed to qualify them forinitial employment in connection with thePipeline System and for advancement to higherpaying positions thereafter.

C. Permittees shall do everythingpracticable to secure the employment, in

connection with the Pipeline System, of thoseAlaska Natives who successfully completePermittees' training program. Permittees shallinform the Authorized Officer of the dischargefrom such employment of each and every AlaskaNative and of the reason therefor, in advance ofsuch discharge whenever possible or, if advancenotice is impossible, as soon thereafter as ispracticable.

D. Permittees shall furnish such informationand reports concerning Alaska Nativeemployment as the Authorized Officer shallrequire from time to time.

30. Native and Other Subsistence

A. To the extent practicable, Permitteesshall not damage any fish, wildlife or bioticresources in the general area of the Right-of-Way upon which Persons living in the area relyfor subsistence purposes; and Permittees willcomply promptly with all requirements andorders of the Secretary to protect the interests ofPersons living in the general area of the Right-of-Way who rely on the fish, wildlife and bioticresources of the area for subsistence purposes.

B. Upon the order of the Secretary,Permittees shall provide emergency subsistenceand other aid, as required by the Secretary, toany affected Alaska Native, Native organizationor other Person pending expeditious filing of,and determination of, a claim by such AlaskaNative, Native organization or other Personunder Section 204(a) of the Trans-AlaskaPipeline Authorization Act. The Secretary'sdecision to issue an order may be based onstatements, made under oath, by such AlaskaNative, Native organization or other Personseeking emergency aid.

31. Termination or Suspension ofRight-of-Way

A. Any failure or refusal of any Permittee,its agents, employees, contractors orsubcontractors (at any tier), or any of them, toobserve or comply substantially with anyapplicable provision of Section 28 of the MineralLeasing Act of 1920, as amended, the Trans-Alaska Pipeline Authorization Act, theregulations of the Secretary implementativethereof, or any provision of this Agreement

APPENDIX F

24

required or authorized by such statutes, shall bedeemed to constitute a breach of thisAgreement, said breach being determined to bejoint and several or several according to theprovisions of Section 21 hereof, and, at theoption of the Secretary, may be grounds fortermination or formal suspension of suchPermittee's interest in the Right-of-Way;provided, however, if, as determined inaccordance with the provisions of Section 21hereof, the breach results in several (as opposedto joint and several) liability, the interest in theRight-of-Way of a Permittee which is not liablefor the breach shall not be subject to terminationor formal suspension on account of the breach.

B. The failure or refusal of Permittees toproceed with reasonable diligence to constructthe Pipeline shall be grounds for termination orformal suspension of the Right-of-Way in aproceeding brought under Section 28(o) of theMineral Leasing Act, as amended; provided,however, that the Right-of-Way shall not beterminated or suspended if the failure to proceedto construct the Pipeline is due to circumstancesbeyond the control of the Permittees.

C. Abandonment of the Right-of-Way shallnot constitute a breach of this Agreement butmay, at the option of the Secretary, be groundsfor termination of the Right-of-Way. Deliberatefailure of Permittees, for any continuous two-year period (whether or not calculated on acalendar-year basis), to use the Right-of-Way forthe purpose for which it was granted shallconstitute a rebuttable presumption ofabandonment of the Right-of-Way. However,where such failure to use the Right-of-Way isdue to circumstances not within Permittees'control, the Secretary is not required tocommence proceedings under Section 28(o) ofthe Mineral Leasing Act of 1920, as amended.

D. Administrative proceedings to terminateor formally suspend the Right-of-Way undersubsections A and B of this Section shall beconducted pursuant to Title 5, United StatesCode, Section 554, and the applicableregulations of the Secretary.

E. Before the Secretary authorizes thecommencement of any administrativeproceeding under Title 5, United States Code,Section 554, for the termination or formal

suspension of any interest in the Right-of-Way,the Authorized Officer shall give the affectedPermittee or Permittees notice in writing of thealleged ground or grounds for termination orformal suspension, with sufficient particularity toenable the Permittee or Permittees to cure if theground or grounds that are alleged constitute abreach of this Agreement. The Permittee orPermittees shall have:

(a) thirty (30) days, in the case of any failureor refusal to pay money, and

(b) sixty (60) days in all other cases, from(and not including) the date of delivery ofthe notice within which to cure thealleged breach or breaches of thisAgreement. If the alleged breach orbreaches (other than with respect to thepayment of money) cannot be curedwithin sixty (60) days, the Permittee orPermittees shall be entitled to suchadditional time as may be necessary tocure; provided, however, that theaffected Permittee or Permittees (whoseinterest in the Right-of-Way would beterminated or formally suspended if theUnited States prevailed in a proceedingto terminate or formally suspend theinterest on the ground or groundsasserted in the notice) first demonstrateto the satisfaction of the AuthorizedOfficer that the necessary curativeactions were undertaken promptly andhave been diligently prosecuted towardscompletion; provided further, that theaforesaid additional time to cure shallnot exceed ninety (90) days from (andnot including) the last day of the saidsixty (60) day period, without the priorwritten consent of the Authorized Officer,which shall specify the last day (to bedetermined by the Authorized Officer)upon which the curative action must becompleted to the satisfaction of theAuthorized Officer. The consent of theAuthorized Officer to additional time (inexcess of the said ninety (90) dayperiod) to cure shall not beunreasonably withheld, and shallnormally be given in situations involvingphysical activities of Permittees inconnection with construction,

APPENDIX F

25

maintenance, operation or termination ofthe Pipeline which Permittees candemonstrate require more time.

F. The foregoing provisions of subsectionE of this Section shall not apply with respect to abreach under any one or more of the followingSections of the Agreement: 20 (Insolvency), 24(Duty of Permittees to Abate), 25 (TemporarySuspension of Activities).

32. Release of Right-of-Way

A. In connection with the relinquishment,abandonment or other termination before theexpiration of the grant of the Right-of-Way, ofany right or interest in the Right-of-Way, and/orin the use of all or any part of the lands subjectto the Right-of-Way, each Permittee holdingsuch right or interest shall promptly execute anddeliver to the United States, through theAuthorized Officer, a valid instrument of releasein recordable form, which shall be executed andacknowledged with, the same formalities as adeed. The instrument of release shall contain,among other things, appropriate recitals, adescription of the pertinent rights and interests,and, for the benefit of the United States and itsgrantees or assigns, express representationsand warranties by the Permittee that it is the soleowner and holder of the rights or interestsdescribed therein and that such rights orinterests are free and clear of all liens, equitiesor claims of any kind requiring or that mayrequire the consent of a third party, claiming inwhole or in part by, through or under thePermittee, for the valid release orextinguishment thereof, except for such that areowned or claimed by third parties which havejoined in the execution of the release. The formand substantive content of each instrument ofrelease shall be approved by the AuthorizedOfficer but, except as otherwise expresslyprovided for above in this subsection in no eventshall any such instrument operate to increasethe then-existing liabilities and obligations of thePermittee furnishing the release.

B. Each release shall be accompanied bysuch resolutions and certifications as theAuthorized Officer may require in connectionwith the power or the authority of the Permittee,or of any officer or agent acting on its behalf, toexecute, acknowledge or deliver the release.

C. Neither the tender, nor the approvaland/or acceptance, of any such release shalloperate as an estoppel or waiver of any claim orjudgment against a Permittee or to relieve ordischarge, in whole or in part, any Permittee ofand from any of its then-existing liabilities orobligations (accrued, contingent or otherwise);and, notwithstanding any such tender ordelivery, or any approval of the AuthorizedOfficer, if a release shall contain any provisionthat operates, or that by implication mightoperate, to discharge or relieve, in whole or inpart, a Permittee of and from any of its liabilitiesor obligations (accrued, contingent or otherwise)or that operates or might operate as an estoppelor waiver of any claim or judgment against aPermittee, or as a covenant not to sue, suchprovision shall be, and shall be deemed to be,void and of no effect whatsoever insofar as itwould have the effect of so discharging orrelieving a Permittee or operating as anestoppel, waiver or covenant not to sue.

33. Agreements Among Permittees

A. The Original Permittees, and each ofthem, represent and covenant with the UnitedStates that they have entered into only thefollowing agreements, and no other agreements,written or oral (excluding prior agreements thatno longer have any force or effect), whichestablish each Original Permittee's interest inthe Pipeline System venture and each OriginalPermittee's relationships with the commonagent, as referred to in Stipulation 1.4, for all orany phase of the construction, operation,maintenance and termination of the PipelineSystem or any part thereof:

(1) Agreement entitled "Trans-AlaskaPipeline System Agreement", dated asof August 27, 1970, by and amongAtlantic Pipe Line Company,* BP Pipe

* ARCO Pipeline Company, a Delaware

corporation, represents and covenants that it is thesuccessor by merger to all of the rights andobligations of Atlantic Pipe Line Company. SohioPipe Line Company, a Delaware corporation,represents and covenants that it is the successor bymerger to all of the rights and obligations of BP PipeLine Corporation. Exxon Pipeline Company, aDelaware corporation, represents and covenants thatit is the same corporation as Humble Pipe LineCompany, but that its name has been duly changed to�Exxon Pipeline Company.�

APPENDIX F

26

Line Corporation,* Humble Pipe LineCompany,* Amerada Hess Corporation,Home Pipe Line Company, Mobil PipeLine Company, Phillips PetroleumCompany, and Union Oil Company ofCalifornia, with Exhibit "C", entitled"Enabling Agreement", annexed thereto;

(2) Agreement entitled "First SupplementalAgreement", dated as of August 27,1970, by the same parties;

(3) Agreement entitled "SecondSupplemental Agreement", dated as ofAugust 27, 1970, by the same parties;

(4) Agreement entitled �Third SupplementalAgreement�, dated as of August 27,1970, by the same parties;

(5) Agreement entitled �FourthSupplemental Agreement�, dated as ofAugust 27, 1970, by the same parties;

(6) Agreement entitled "Fifth SupplementalAgreement" dated as of August 27,1970, by the same parties;

(7) Agreement entitled �Agreement for theDesign and Construction of the Trans-Alaska Pipeline System� dated as ofAugust 27, 1970, by and among AtlanticPipe Line Company, BP Pipe LineCorporation, Humble Pipe LineCompany, Amerada Hess Corporation,Home Pipe Line Company, Mobil PipeLine Company, Phillips PetroleumCompany, Union Oil Company ofCalifornia, and Alyeska Pipeline ServiceCompany;

(8) Agreement entitled "ShareholdersAgreement for Alyeska Pipeline ServiceCompany", dated as of August 27, 1970,by the same parties as those listed withrespect to the agreement referred toimmediately above;

(9) Assignment, Assumption, Release andConsent Agreement, dated as ofAugust 28, 1970, in connection with thetransfer by Home Pipe Line Company tothe other participating companies of allof its rights, title, and interest in the

Pipeline System and in the foregoingagreements, and as a shareholder inand to Alyeska Pipeline ServiceCompany.

(10) Assignment, Conveyance, and TransferAgreement, dated December 11, 1973,in connection with the transfer by MobilPipe Line Company to Mobil AlaskaPipeline Company, a DelawareCorporation, of all of the formercompany's rights under all agreementsrelating to the Trans-Alaska PipelineSystem, to which the former company isa party, and all real or personalproperty in which the former companymay have acquired an ownershipinterest pursuant to such agreements,and under which Assignment,Conveyance and Transfer AgreementMobil Alaska Pipeline Companyassumes all undischarged obligationsof Mobil Pipe Line Company under anyand all of the above mentioned Trans-Alaska Pipeline System agreements,together with certain supportingdocuments (five in number) each datedDecember 11, 1973; and

(11) Assignment, Conveyance, and TransferAgreement, dated January 8, 1974, inconnection with the transfer by UnionOil Company of California to UnionAlaska Pipeline Company, a CaliforniaCorporation, of all of the formercompany's rights under all agreementsrelating to the Trans-Alaska PipelineSystem to which the former company isa party, and all real or personalproperty in which the former companymay have acquired an ownershipinterest pursuant to such agreements,and under which Assignment,Conveyance and Transfer AgreementUnion Alaska Pipeline Companyassumes all undischarged obligationsof Union Oil Company of Californiaunder any and all of the abovementioned Trans-Alaska PipelineSystem agreements.

B. Said agreements are referred tocollectively as the "Ownership Agreements."Each affected Permittee shall file promptly with

APPENDIX F

27

the Authorized Officer true and complete copiesof all modifications of the OwnershipAgreements and of all instruments superseding,supplementing, canceling or rescinding, in wholeor in part, any one or more of the OwnershipAgreements.

C. In the event Permittees execute an"Operating Agreement", as contemplated inSection 5.1 of the agreement described insubsection A (l) above in this Section, or any likeor similar agreement with respect to theoperation, maintenance, or termination of all orany part of the Pipeline System, Permittees shallfile promptly with the Authorized Officer a trueand complete copy thereof, together with likecopies of all modifications of, and all agreementssuperseding, supplementing, canceling orrescinding, in whole or in part, the OperatingAgreement or any such like or similaragreement.

34. Access to Documents

A. As to any documents or records not filed(or required to be filed under any other provisionof this Agreement) with the Secretary or theAuthorized Officer that shall be relevant to theexercise or enforcement by the Secretary of hisauthority or the rights of the United States underor in connection with this Agreement or withrespect to all or any part of the Pipeline Systemthe Secretary shall have the right, after notice tothe affected Permittee, to inspect and copy:(1) any document or record which a Permittee isrequired by this Agreement to make or maintain,(2) any document or record that at any time hasbeen filed by a Permittee with any governmentaldepartment or agency, access to which is notprohibited or limited by law or regulation, or(3) any abstract, summary or other documentthat may have been prepared by anygovernmental department or agency inconnection with any document or record referredto in (2) above.

B. Subject to the requirement that thedocuments or records, herein below referred to,shall be relevant to the exercise or enforcementby the Secretary of his authority or the rights ofthe United States under or in connection withthis Agreement or with respect to all or any partof the Pipeline System, the Secretary, afternotice to the affected Permittee, may inspect

and, with the consent of the affected Permittee(which consent each Permittee agrees will notbe unreasonably withheld or delayed), may copyany document or record that has been or mayhereafter be filed by a Permittee with anygovernmental agency, access to which isprohibited or limited by law or regulation, andany abstract, summary or other document thatmay have been prepared by a governmentaldepartment or agency in connection with anysuch document or record; provided, however,that the rights of the Secretary under thissubsection may be exercised only if, and to theextent that, this provision constitutes a validwaiver of any such prohibition or limitation.

C. Nothing in this Section shall be deemedto limit, prohibit, or waive any right or privilege ofthe United States, and particularly of theSecretary, to inspect or copy any document orrecord under any authority granted pursuant tolaw or regulations.

35. Rights of Third Parties

The parties hereto do not intend to createany rights under this Agreement that may beenforced by third parties for their own benefit orfor the benefit of others.

36. Covenants Independent

Each and every covenant contained in thisAgreement is, and shall be deemed to be,separate and independent of, and not dependenton, any other covenant contained in thisAgreement.

37. Partial Invalidity

If any part of this Agreement is held invalidor unenforceable, the remainder of thisAgreement shall not be affected and shall bevalid and enforced to the fullest extent permittedby law.

38. Waiver Not Continuing

The waiver by any party hereto of anybreach of any provision of this Agreement by anyother party hereto, whether such waiver beexpressed or implied, shall not be construed tobe a continuing waiver or a waiver of, or consentto, any subsequent or prior breach on the part of

APPENDIX F

28

such other party, of the same or any otherprovision of this Agreement.

39. Remedies Cumulative; EquitableRelief

Except as otherwise expressly provided insubsections B and D of Section 13 of thisAgreement, no remedy conferred by thisAgreement upon or reserved to the UnitedStates or to Permittees is intended to beexclusive of any other remedy provided for bythis Agreement or by law, but each shall becumulative and shall be in addition to everyother remedy given hereunder or now orhereafter existing in equity or at law; and theUnited States, in a proper action instituted by it,may seek a decree against a Permittee orPermittees for specific performance, injunctive orother equitable relief, as may be appropriate.

40. Section Headings

The section headings in this Agreement arefor convenience only, and do not purport to, andshall not be deemed to, define, limit or extendthe scope or intent of the section to which theypertain.

41. Authority to Enter Agreement

Each Original Permittee represents andwarrants to the United States that: (1) and by itscharter and by-laws to enter into and performthis Agreement in accordance with theprovisions hereof; (2) its board of directors, orduly authorized executive committee, has dulyapproved, and has duly authorized, theexecution, delivery and performance by it of thisAgreement; (3) all corporate and shareholderaction that may be necessary or incidental to theapproval of this Agreement, and the due

execution, delivery and performance hereof byPermittee, has been taken; and (4) that all of theforegoing approvals, authorizations and actionsare in full force and effect at the time of theexecution and delivery of this Agreement.

IN WITNESS WHEREOF, the parties heretohave duly executed this Agreement as of thedate first above written.

United States of America By /s/ Gale Norton Secretary of the Interior

Amerada Hess Pipeline Corporation By /s/ Title

BP Pipelines (Alaska) Inc. By /s/ Title

ExxonMobil Pipeline Company By /s/ Title

Phillips Transportation Alaska, Inc. By /s/

Unocal Pipeline Company By /s/ Title

Williams Alaska Pipeline Company,L.L.C. By /s/ Title

APPENDIX F

EXHIBIT A

Federal Grant of Right-of-WayF-12505 and AA-5847

Legal Description

APPENDIX F

APPENDIX F

A-1

EXHIBIT A

Federal Grant of Right-of-Way F-12505 andAA-5847 Legal Description

Those lands within the Trans Alaska PipelineSystem Right-of-Way as described in:

Plats 81-1 (TAPS Centerline MonumentationSurvey) filed January 7, 1981 in the Barrow,Fairbanks, Fort Gibbon and RampartRecording Districts, respectively, and filedon January 12, 1981 in the Chitina andValdez Recording Districts, respectively,

Plats 2001-8 and 2001-5 (TAPS CenterlineMonumentation Survey at Atigun Reroute,MP 200 Reroute and Pump Station [�P.S.�]6 vicinity) filed January 10, 2001 in theBarrow and Fairbanks Recording Districts,respectively,

Plat 95-3 (P.S. 4) filed February 23, 1995 inthe Barrow Recording District,

Plats 95-11 (P.S. 5) and 95-14 (P.S. 10) filedFebruary 23, 1995 in the FairbanksRecording District,

Plat 95-04 (P.S. 11) filed February 27, 1995in the Chitina Recording District,

Plat 95-04 (P.S. 12) filed February 21, 1995in the Valdez Recording District,

Plats 2001-6 (Communication Site (C.S.)Atigun) and 2001-7 (C.S. Margaret Hill) filedJanuary 10, 2001 in the Barrow RecordingDistrict,

Plats 2000-14 (C.S. Gakona) and 2000-15(C.S. Stuck) filed December 27, 2000 in theChitina Recording District,

Plats 2001-6 (C.S. Kaaruk), 2001-7 (C.S.Coldfoot), 2001-8 (C.S. Eagle), 2001-9 (C.S.Fish), 2001-11 (C.S. Aggie), 2001-12 (C.S.Donnelly), 2001-13 (C.S. Nicole Knob) and2001-14 (C.S. Yost) filed January 10, 2001in the Fairbanks Recording District,

Plat 2001-1 (C.S. Bench) filed January 10,2001 in the Rampart Recording District,

Plats 2001-17 (C.S. Kimball Pass), 2001-19(C.S. Tiekel) and 2001-20 (C.S. Tsina) filedDecember 28, 2000 in the Valdez RecordingDistrict,

And further described in the TAPS Right-of-Way Boundary Description Report, AlyeskaManual No. ROW 214, as amended.

To the extent such lands are located with thefollowing described townships:

UMIAT MERIDIAN

T. 1 S., R. 14 E., Sec. 2 E½ Sec. 10 SE¼ Sec. 11 Sec. 15 NE¼

T. 9 S., R. 13 E., Sec. 4, 5, 8, 7

T. 9 S., R. 12 E., Sec. 11, 12, 14, 15, 16, 17, 19, 20, 30

T. 9 S., R. 11 E., Sec. 25, 35, 36,

T. 10 S., R. 11 E., Sec. 2, 3, 10, 11, 14, 23, 26, 35

T. 11 S., R. 11 E., Sec. 1, 2, 12, 13, 24

T. 11 S., R. 12 E., Sec. 19, 29, 30, 32

T. 12 S., R. 12 E., Sec. 5, 8, 9, 16, 21, 28, 33

T. 13 S., R. 12 E., Sec. 3, 9, 10, 15, 16, 21, 28, 33, 32

T. 14 S., R. 12 E., Sec. 5, 7, 8, 17, 20, 29, 32

APPENDIX F

A-2

T. 15 S., R. 12 E., Sec. 5, 6, 7, 17, 18, 19

T. 15 S., R. 11 E., Sec. 23, 24, 26, 35, 34

T. 16 S., R. 11 E., Sec. 2, 3, 9, 10, 16, 19, 20, 21, 29, 30

T. 16 S., R. 10 E., Sec. 25, 35, 36, Sec. 33 NE¼, Sec. 34 NW¼

T. 17 S., R. 10 E., Sec. 2

FAIRBANKS MERIDIAN

T. 37 N., R. 10 W., Sec. 25, 26, 35

T. 36 N., R. 10 W., Sec. 2, 3, 10, 15, 16, 21, 28, 33

T. 35 N., R. 10 W., Sec. 4, 9, 16, 21, 28, 33

T. 34 N., R. 10 W.,Sec. 4, 9, 10, 15, 22, 27, 26, 35

T. 33 N., R. 10 W., Sec. 2, 11, 13, 14, 21, 24, 25, 26, 35, 34

T. 32 N., R. 10 W., F.M. Sec. 4, 9, 16, 21, 20, 29, 32, 31

T. 31 N., R. 10 W., Sec. 6, 7, 8, 18, 19

T. 31 N., R. 11 W., Sec. 25, 26, 35, 34, 33, 32

T. 30 N., R. 11 W., Sec. 5, 6, 7, 18, 19, 30

T. 30 N., R. 12 W., Sec. 25, 36

T. 29 N., R. 12 W., Sec. 1, 11, 12, 13, 14

T. 28 N., R. 12 W., Sec. 6 SE¼ Sec. 15 and 16, those portions

within federal mining claimF-63334

Sec. 29, 30, 31

T. 27 N., R. 12 W., Sec. 6

T. 27 N., R. 13 W., Sec. 1, 11, 12, 14, 23, 26, 35

T. 26 N., R. 13 W., Sec. 2, 11, 14, 23, 26, 25, 36

T. 25 N., R. 14 W., Sec. 35 NW¼

T. 25 N., R. 13 W., Sec. 1, 12, 13, 23, 24, 26, 27, 33, 34

T. 25 N., R. 12 W., Sec. 6, 7

T. 24 N., R. 13 W., Sec. 5, 7, 8, 18

T. 24 N., R. 14 W., Sec. 13, 23, 24, 26, 27, 34

T. 23 N., R. 14 W., Sec. 3, 4, 8, 9 17, 18, 19, 30, 31

T. 22 N., R. 14 W., Sec. 6, 7, 18, 19, 20, 29, 32

T. 21 N., R. 14 W., Sec. 5, 6, 7, 18, 19, 30, 31

T. 20 N., R. 13 W., Sec. 30 SW¼

T. 20 N., R. 15 W., Sec. 2, 10, 11, 15, 22, 26, 27, 35

T. 19 N., R. 15 W., Sec. 2, 11, 12, 13, 24

T. 19 N., R. 14 W., Sec. 19, 30, 31, 32

APPENDIX F

A-3

T. 18 N., R. 14 W., Sec. 4, 5, United States Survey (�USS�) 6892, Lot 6

(in Sec. 9) Sec. 9, 10, 14, 15, 23, 25, 26, 36

T. 17 N., R. 14 W., Sec. 1

T. 17 N., R. 13 W., Sec. 6, 7, 8, 17, 20, 21, 28, 33, 34

T. 16 N., R. 13 W., Sec. 3, 4, 10, 15, 14, 23, 24, 25, 36

T. 16 N., R. 12 W., Sec. 31

T. 15 N., R. 12 W., Sec. 6, 7, 17, 18, 20, 29, 30, 31

T. 14 N., R. 11 W., Sec. 26

T. 14 N., R. 12 W., Sec. 6, 7, 8, 17, 20, 21, 27, 28, 34, 35

T. 13 N., R. 12 W., Sec. 1, 2, 12

T. 13 N., R. 11 W., Sec. 7, 17, 18, 20, 21, 22, 26, 27, 35, 36

T. 12 N., R. 11 W., Sec. 1

T. 12 N., R. 10 W., Sec. 6 Sec. 7, those portions above the

Ordinary High Water (�OHW�)line on the north bank of theYukon River

T. 5 N., R. 3 W., Sec. 27, 34 Sec. 36 SE¼, those portions within

the White Mountains NationalRecreation Area

T. 2 N., R. 1 W., Sec. 3 and 10, those portions within federal

mining claims F-52189, F-52176,F-52172 and F-52185

T. 1 S., R. 2 E., Sec. 22 Sec. 26, 27

T. 2 S., R. 2 E., Sec. 13 and 24, those portions within the Chena River Lakes Flood Control Project

T. 2 S., R. 3 E., Sec. 19 excluding USS 9074, Lots 2 & 3 USS 9074, Lots 2 & 3 (in Section 19) Sec. 20 Sec. 21, those portions

within the Chena River LakesFlood Control Project

Sec. 26, 27 E½, 35, 36

T. 3 S., R. 3 E., Sec. 1, 12

T. 3 S., R. 4 E., Sec. 7, 18, 17, 20, 21, 28, 33, 34

T. 4 S., R. 4 E., Sec. 2 NW¼, N½SW¼ Sec. 3 NE¼

T. 10 S., R. 10 E., Sec. 2 NE¼SW¼ Sec. 11 SW¼SE¼NE¼, NE¼SE¼ USS 3293 A and B, Streets and Block 18

(Federal Reserve) (in Section 24) USS 2626, Lot 2 (in Sec. 25, 26, 35)

T. 11 S., R. 10 E., USS 2626 (in Sec. 2, 11) Sec. 10, 11, 15, 22 Sec. 27 N½N½N½N½ Sec. 34 NE¼NW¼, S½NW¼

APPENDIX F

A-4

T. 12 S., R. 10 E., Sec. 3, those portions east of the

Richardson Highway, excludingLots 30, 32 and 38

Sec. 10, those portions east of theRichardson Highway

Sec. 15 SW¼NW¼, excluding Lot 20,NW¼SW¼

Sec. 16 Sec. 21, 28, 32, 33

T. 13 S., R. 10 E., Sec. 4, 9, 16, 21 Sec. 28 and 29, those portions lying

north of a line ½ mile northof the Richardson Highway

T. 14 S., R. 10 E., Sec. 5, 8, 17, 20, 29, 32

T. 15 S., R. 9 E., Sec. 27

T. 15 S., R. 10 E., Sec. 6 S½ Sec. 7, 18, 19, 29, 30, 32

T. 16 S., R. 10 E., Sec. 5, 8, 17, 20, 29, 32

T. 17 S., R. 10 E., Sec. 4, 9, 10, 14, 15, 23, 24, 25, 36

T. 18 S., R. 10 E., Sec. 1, 12, 13, 24, 25, 36

T. 19 S., R. 10 E., Sec. 1, 12, 13

T. 19 S., R. 11 E., Sec. 18, 19, 20, 21, 29, 32

T. 22 S., R. 12 E., Sec. 4, 9, 16, 21, 28 29, 32

COPPER RIVER MERIDIAN

T. 14 N., R. 1 W., Sec. 31

T. 13 N., R. 1 W., Sec. 5, 6, 8, 17, 18, 20

T. 12 N., R. 1 W., Sec. 5, 8, 17, 20, 29, 32, 33

T. 11 N., R. 1 W., Sec. 4, 9, 16, 21, 28, 32, 33

T. 10 N., R. 1 W., Sec. 5, 8, 7, 18, 17, 20, 29, 32, 31

T. 9 N., R. 1 W., Sec. 6, 7T. 9 N., R. 2 W., Sec. 12, 13 Sec. 23, Lot 6 Sec. 24 NW¼, W½SW¼ Sec. 25 NW¼NW¼ Sec. 26, S½, Lots 1, 4, 5 Sec. 35

T. 8 N., R. 2 W., Sec. 2, 11, 14, 23, 24, 25, 36

T. 7 N., R. 2 W., Sec. 1, 12, 13, 24, 25, 36

T. 7 N., R. 1 W., Sec. 6 Sec. 35 NW¼, those portions east of

the Richardson Highway

T. 6 N., R. 2 W., Sec. 1, 12, 13, 24, 25, 36

T. 5 N., R. 2 W., Sec. 1, 12, 13, 24, 25 USS 10679, Lot 2 (in Sec. 25, 36) Sec. 36

T. 4 N., R. 2 W., Sec. 1, 12, 13 Sec. 24 N½S½ and Lots 43 and 44 Sec. 25

T. 4 N., R. 1 W., Sec. 30 W½ Sec. 31

T. 2 N., R. 1 W., Sec. 3, 10, 11, 24, 25

T. 2 N., R. 1 E., Sec. 30, 31

APPENDIX F

A-5

T. 1 N., R. 1 E., Sec. 6 Lot 3, SE¼NW¼, SE¼

T. 1 S., R. 1 E., Sec. 4 Lot 1 Sec. 3 Lot 4 and S½NW¼, E½SE¼SW¼,

SW¼SW¼SE¼ Sec. 8 SE¼ Sec. 10, 14, 15 Sec. 23 excluding E½SW¼NW¼NE¼

and S½SE¼SE¼ Sec. 25 SW¼NW¼ Sec. 26 E½SE¼NE¼, E½E½SE¼ Sec. 35 NE¼

T. 2 S., R. 1 E., Sec. 2 Lot 2, SW¼NE¼, Lot 6,

Lot 7, E½SW¼ Sec. 11 W½NE¼NW¼, Lot 2,

Lot 4, W½SW¼ Sec. 14 W½NW¼ Sec. 15 Sec. 22, 27, 34

T. 3 S., R. 1 E., Sec. 3 Sec. 4 SE¼ Sec. 9, 16, 21, 28 Sec. 29 SE¼SE¼SE¼ Sec. 32, 33 NW¼NW¼NW¼

T. 4 S., R. 1 E., Sec. 5, 8, 17, 16, 21, 22 Sec. 27 N½, N½S½ Sec. 26, 25, 36

T. 4 S., R. 2 E.,Tract A

T. 5 S., R. 1 E., Sec. 1, 12, 13, 23, 24, 26, 27, 32, 33, 34

T. 5 S., R. 2 E., Sec. 6, 7

T. 6 S., R. 1 E., Sec. 5, 8, 7, 17, 18, 29, 30, 32

T. 6 S., R. 1 W., Sec. 13, 24, 25

T. 7 S., R. 1 E., Sec. 5, 8, 17, 18

T. 7 S., R. 1 W., Sec. 13, 23, 24, 26, 27, 34 Sec. 35 NE¼

T. 8 S., R. 1 W., Sec. 3, 4, 5, 6

T. 8 S., R. 2 W., Tract A (those portions comprising

Sec. 1, 2, 3, 4, 7, 8, 9)

APPENDIX F

A-6

APPENDIX F

Exhibit B

Requirements of the Department of DefenseRelating to Military Installations

APPENDIX F

APPENDIX F

B-1

EXHIBIT B

Requirements of the Department of DefenseRelating to Military Installations

A. General Requirements

1. Entry upon military land for constructionand routine operations and maintenance shall befully coordinated ten (10) days in advance ofentry with the appropriate installationcommander having immediate jurisdiction overthe property. Entry under emergency conditionsshall be coordinated expeditiously with theinstallation commander.

2. Entry for all activities conducted byPermittees upon all military installations shall bein strict compliance with post/base regulations,both existing or hereafter promulgated.Permittees shall obtain copies of suchregulations from the affected installationcommanders.

3. Ingress and egress to militaryinstallation shall be confined to routesdesignated by the installation commander. Suchcommander shall have the right to modify orchange the designated routes without advancenotice to Permittees. Use of existing militaryroads or other access routes across subjectlands shall be non-exclusive.

4. Permittees shall reimburse the UnitedStates, through the Army or Air Force installationaffected, for any increased maintenance costs ofexisting military roads resulting from orattributable to usage by Permittees. These costsshall be in addition to those contemplated bySection 12 of this Agreement.

5. Permittees may construct permanentaccess and maintenance roads within the Right-of-Way, provided such roads do not interferewith the surface use of the area by the military,except during the construction phase.

6. Roads designated by the installationcommander to require intermittent military usagemay be closed. The installation commandershall approve in advance all such closures. Anyextended closure shall cause the road to be

treated as stated in Section 3 of these GeneralRequirements.

7. Any overhead construction relating tothe Pipeline shall provide for a minimum ofeighteen (18) feet of clearance above theexisting road surface.

8. Crossover road ramp constructionrelative to ramp grades, pipeline cover, sleeves,bridging, signs and the like will conform to theextent practical to the standards of the AlaskaState Highway Department.

9. Final route selection, as mapped, andany subsequent changes thereto across militarylands will be approved by the affectedinstallation commander prior to construction.The route of the Pipeline shall be located so asto avoid military improvements and the Pipelineshall be constructed a minimum distance ofthree hundred and twenty-five (325) feet fromperimeter fences surrounding ammunition andfuel storage areas.

10. No surface projection of the Pipelineshall be permitted within the drop zone areawest of the main development at Fort Greely.

11. Crossing of Army Petroleum Oil andLubricant (POL) line will be coordinated with theaffected installation commander and thePetroleum Distribution Office (PDO), SupportCommand, U.S. Army, Alaska (USARAL),Fort Richardson, Alaska.

12. The Pipeline traversing subject landsshall be buried from stations 8400+00 and to8511+51 and from Stations 8554+70 to 8562+46as shown on Alyeska Pipeline Service CompanyTrans Alaska Pipeline System Drawing AL-00-G2, Sheet 45 of 138, Prudhoe Bay to Valdez.Burial depth and technique shall be sufficient topermit surface crossing of the Right-of-Way byheavy tracked and wheeled vehicles atdesignated locations of existing roads andrunways. In the event that subsurface

APPENDIX F

B-2

construction cannot be accomplished to thesatisfaction of the installation commander, thePipeline shall be relocated to an area or areaswhere burial is permissible, or where surfaceconstruction can by authorized withoutinterruption of the military mission. Mode ofconstruction between the aforementionedstations shall require the prior consent of theinstallation commander.

13. Disruption of, or interference with theoperation and maintenance of any militarypipelines, utility and communication lines isprohibited except by authorization by theinstallation commander. The Pipeline shallcross all existing intersecting pipelines, conduits,and cables with a minimum clearance of twelve(12) inches.

14. Maximum length of open trench ortrenches during construction of the Pipeline overand across the subject land shall not exceed one(1) mile at any given time without the priorapproval of the installation commander.

15. Suitable bridged crossings over opentrenches shall be provided and maintainedwhere necessary to permit passage of militarypersonnel and vehicles; timely notice ofrequirements to be furnished by installationcommander.

16. In connection with Permittees� duties torepair, replace, and rehabilitate as provided forin Section 13 of this Agreement, where borrowedsoil material is necessary to perform such duties,the location and method of obtaining theborrowed material shall be approved by theinstallation commander. All surplus material notrequired for fill, backfill or grading shall bespread and leveled in an area designated bysaid commander.

17. Permittees shall submit legaldescriptions of the centerline of the Right-of-Wayand permanent access and maintenance roadsas constructed in, upon, over and acrossmilitary-controlled lands to the installationcommander within ninety (90) days of thecompletion of construction within a given militaryinstallation. Separate legal descriptions shall bewritten for each noncontiguous tract of military-controlled land. Said legal descriptions shall beaccompanied by preliminary �as built� drawings

(and final �as built� drawings shall be furnishedwithin three hundred and sixty (360) days) ofsaid completion of the Pipeline and allpermanent access and maintenance roads,together with separate real estate maps in theevent sufficient survey information necessary toverify legal descriptions is not contained on the�as built� drawings.

18. Permittees shall install mainline valvessufficient to control Oil flow in the vicinity ofpopulated area, ammunition/explosive and fuelstorage areas.

19. Electrically operated devices installed aspart of the Pipeline System which are capable ofproducing radiations, electromagnetic or otherinterference, shall be screened, filtered orotherwise suppressed to the extent that suchdevices will not adversely affect the function ofexisting communication systems. In the eventthat physical obstructions, such as towers orbuildings are to be erected as part of thePipeline System, their positioning shall be suchthat they will not obstruct radiation patterns ofline-of-site communication, navigation aids orother communications, electronic ormeteorological services.

20. Entry for construction and routinemaintenance upon installations or crossings ofutility facilities under the control of or utilized byAir Force Communications System/White Alicewill be coordinated at least ten (10) days prior toentry with Alaska Communications Regionthrough Headquarters, Alaskan Air Command,Elmendorf Air Force Base. Entry underemergency conditions will be coordinatedexpeditiously with the Region.

21. Should the Pipeline cross high voltagepower transmission lines on Eielson Air ForceBase, adequate precaution to the satisfaction ofthe installation commander will be taken toinsure that excessive sag or accidental powerline breakage does not create a safety hazard.

22. In the event unexploded munitions arediscovered by Permittees during constructionactivities, the construction activities shallimmediately cease in that area. Permittees shallnotify the installation commander who willimmediately proceed to dispose of the

APPENDIX F

B-3

munitions. Construction shall not proceed untilauthorized by the installation commander.

23. The United States reserves to itself theright to construct, use and maintain across, overand/or under the Right-off-Way, oil and sewerlines, and other facilities, in such manner as notto create an unreasonable interference with theuse of the Right-of-Way.

24. Any authorized use or occupation of thesubject military lands in connection with theconstruction, operation, maintenance ortermination of the Pipeline System shall besubject to such rules and regulations as theinstallation commanders may from time to timeprescribe. The military departments reserve theright to modify or change conditions to protectmilitary interests as circumstances may fromtime to time warrant.

25. Transportation, storage and use ofexplosives during construction of the PipelineSystem shall be permitted only in conformancewith the applicable installation regulations.Permittees shall secure copies of theseregulations from the installation commanders.Use of all explosives on military reservationsshall be in strict conformance with U.S. ArmyCorps of Engineers Safety Manual, andPermittees shall secure copies of this manualfrom the installation commander. At least thirty(30) days in advance of any underwater blasting,Permittees shall submit to the installationcommander a plan for such blasting. The planshall set forth blasting locations, types andamounts of explosives, date or dates of blasting,and the reason for blasting.

26. The use of pesticides and herbicidesshall be in accordance with applicable militaryregulations. An approved list of pesticides and

herbicides, together with application constraintsshall be obtained from the installationcommander.

27. Permittees shall locate and/or install thePipeline System in such manner so as topreclude the creation of ground fog and/or icefog conditions which will in any way decreasethe operational capability of the air fields locatedon Eielson Air Force Base, Fort Wainwright andFort Greely. Studies or other data supporting thelocation or construction techniques utilized byPermittees to accomplish the requirements ofthis condition shall be submitted to theinstallation commander for review and approvalthirty (30) days prior to commencement ofconstruction on the lands herein described.

28. Prior to commencement of construction,Permittees shall submit a schedule of theirconstruction activities on the military installationinvolved. This schedule shall be in such detailas may be required by the installationcommander and during the course ofconstruction this schedule shall be updated andresubmitted as may be required by theinstallation commander.

B. Definitions

As used above, the following items have themeanings indicated:

1. �Installation Commander�: TheCommanding Officer of a militaryinstallation, E.g., Fort Wainwright, FortGreely, Eielson Air Force Base.

2. �District Engineer�: The DistrictEngineer, U.S. Army Engineer District,Alaska, Anchorage, Alaska

APPENDIX F

B-4

DEPARTMENT OF THE ARMYOFFICE OF THE CHIEF OF ENGINEERSWASHINGTON, D.C., November 23, 1973

Mr. DAVID E. LINDGREENDeputy SolicitorDepartment of the Interior,Washington, D.C.

DEAR MR. LINDGREEN: By letter dated 14 November 1973 we furnished you certainprovisions to be included in the right-of-way permit for the construction of the Trans-Alaska Pipeline. These provisions protect military interests where the pipeline right-of-way crosses or otherwise affects military installations.

In this letter we reserved the right to make reasonable modifications or changes fromtime to time. We are furnishing herewith a revision of Exhibit E which clarifies the intentof various paragraphs and eliminates certain paragraphs in which the provision is alreadyadequately covered in the stipulations of the Final Environmental Impact Statement.

It is the intention of the Department of the Army and the Department of the Air Forceto permit the construction, operation, maintenance, and termination of the Trans-AlaskaPipeline in a way that is compatible with both military operations and the Pipeline System,and that the necessary approvals requested by the Pipeline System will not beunreasonably withheld.

Sincerely,WOODROW BERGE

Director of Real Estate.

Note--The �revision� referred to above in this letter was modified in certain respectsbefore being incorporated into this Agreement and the Director of Real Estate, D.O.A.,Office of Chief of Engineers, has been apprised of the modifications in all materialrespects.

APPENDIX F

B-5

DEPARTMENT OF THE ARMY OFFICE OF THE CHIEF OF ENGINEERS, Washington, D.C., November 14, 1973

MR. DAVID E. LINDGREENDeputy SolicitorDepartment of the InteriorWashington, D.C.

DEAR MR. LINDGREEN: This refers to our DAEN-CWZ-W letter dated 9 November1973 concerning review of your 20 July 1973 draft permit on the construction of theTrans-Alaska Pipeline. We indicated then that the permit should contain conditions toprotect military interests where the pipeline right-of-way crosses or otherwise affectsmilitary installations.

We have prepared and are inclosing a set of such provisions to be incorporated in thedraft permit as Exhibit E.

While these conditions are as accurate as we can foresee at this time, militaryexigencies and local circumstances may require that reasonable modifications orchanges be made from time to time and the discretion to make such changes has beenreserved in our proposedExhibit E.

Sincerely,WOODROW BERGE

Director of Real Estate.

APPENDIX F

B-6

APPENDIX F

EXHIBIT C

Requirements of the Federal PowerCommission Relating to Power Sites

(Exhibit is proposed for deletion because there no longer are lands in the TAPS ROW classified,withdrawn, or reserved for power purposes. Deletion is pending confirmatory discussions.)

APPENDIX F

APPENDIX F

C-1

EXHIBIT C

Requirements of the Federal Power CommissionRelating to Power Sites

A. With respect to any Federal Lands thatare classified, withdrawn or reserved for powerpurposes, the grant of the Right-of-Way is, inaccordance with the findings of the FederalPower Commission (Docket No. DA-112-Alaska, U.S. Department of the Interior, issuedon December 6, 1973), made subject to:

* * * the retention of prior rights for reservoiror power development, and subject to thecondition that in the event the said land is

required for such purposes, any improvementsor structures placed thereon which shall befound to interfere with such development shallbe removed or relocated as may be necessary toeliminate interference with reservoir or powerdevelopment at no cost to the United States, itspermittees or licensees.

B. The Permittees herein shall not bedeemed to be "permittees or licensees" withinthe meaning of the aforesaid findings of theFederal Power Commission.

APPENDIX F

C-2

APPENDIX F

EXHIBIT D

Stipulations for the Agreement and Grant ofRight-of-Way for the Trans-Alaska Pipeline

APPENDIX F

APPENDIX F

D-1

EXHIBIT D

Stipulations for the Agreement and Grant of Right-of-Way for the Trans-Alaska Pipeline

Table of Contents

Page1 GENERAL1.1 Definitions .............................................................................................................................. D-21.2 Responsibilities ...................................................................................................................... D-41.3 Authorized Officer................................................................................................................... D-51.4 Common Agent of Permittees ............................................................................................... D-51.5 Authority of Representatives of Authorized Officer and Common Agent; Orders

of Authorized Officer .............................................................................................................. D-61.6 Orders and Notices ............................................................................................................... D-61.7 Notices To Proceed ............................................................................................................... D-71.8 Changes in Conditions ........................................................................................................... D-91.9 Antiquities and Historical Sites ............................................................................................... D-91.10 Completion of Use ................................................................................................................. D-91.11 Public Improvements.............................................................................................................. D-101.12 Regulation of Public Access................................................................................................... D-101.13 Electronically Operated Devices ............................................................................................ D-101.14 Camping, Hunting, Fishing, and Trapping .............................................................................. D-101.15 Small Craft Passage............................................................................................................... D-111.16 Protection of Survey Monuments ........................................................................................... D-111.17 Fire Prevention and Suppression ........................................................................................... D-111.18 Surveillance and Maintenance ............................................................................................... D-111.19 Housing and Quarters ........................................................................................................... D-111.20 Health and Safety................................................................................................................... D-111.21 Conduct of Operations ........................................................................................................... D-121.22 Applicability of Stipulations..................................................................................................... D-122 ENVIRONMENTAL2.1 Environmental Briefing ........................................................................................................... D-122.2 Pollution Control ..................................................................................................................... D-122.3 Buffer Strips............................................................................................................................ D-132.4 Erosion Control ...................................................................................................................... D-132.5 Fish and Wildlife Protection ................................................................................................... D-142.6 Material Sites.......................................................................................................................... D-152.7 Clearing.................................................................................................................................. D-152.8 Disturbance of Natural Water ................................................................................................. D-152.9 Off Right-of-Way Traffic ......................................................................................................... D-162.10 Aesthetics............................................................................................................................... D-162.11 Use of Explosives................................................................................................................... D-162.12 Restoration ............................................................................................................................ D-162.13 Reporting of Oil Discharges ................................................................................................... D-162.14 Contingency Plans ................................................................................................................ D-163 TECHNICAL3.1 General .................................................................................................................................. D-173.2 Pipeline System Standards .................................................................................................... D-173.3 Construction Mode Requirements .......................................................................................... D-183.4 Earthquakes and Fault Displacements................................................................................... D-193.5 Slope Stability ........................................................................................................................ D-203.6 Stream and Flood Plain Crossings and Erosion ........................................................ D-203.7 Sea Waves................................................................................................................. D-213.8 Glacier Surges ........................................................................................................... D-213.9 Construction and Operation ....................................................................................... D-213.10 Pipeline Corrosion...................................................................................................... D-213.11 Containment of Oil Spills ........................................................................................... D-22

APPENDIX F

D-2

1. GENERAL

1.1. Definitions

1.1.1. As used in these Stipulations andelsewhere in this "Agreement and Grant ofRight-of-Way for Trans-Alaska Pipeline", thefollowing terms have the following meanings:

1.1.1.1. "Access Roads" means the roadsconstructed or used by Permittees within, or foringress to and egress from, the Pipeline System.It does not include the proposed State highwayfrom the Yukon River to Prudhoe Bay, Alaska, orany other State highway.

1.1.1.2. "Affiliate" means (a) a Subsidiaryof a Parent, or (b) the Parent of the Subsidiary,or (c) in the case of a corporate Subsidiary, oneor more corporations that share the Parent withthe Subsidiary by reason of the fact that all of theoutstanding capital stock of each of thecorporations that share the Parent is owneddirectly or indirectly by the Parent, or (d) in thecase of Sohio Pipe Line Company, anycorporation of which all of the outstanding capitalstock is owned directly or indirectly by TheStandard Oil Company, an Ohio corporation, orThe British Petroleum Company, Limited, aUnited Kingdom corporation, or both.

1.1.1.3. "Authorized Officer" means theemployee of the Department, designated by theSecretary, to whom the Secretary delegates theauthority to act on behalf of the Secretarypursuant to this Agreement or such other Personto whom the Authorized Officer redelegates hisauthority pursuant to the delegation of authorityto the Authorized Officer from the Secretary.

1.1.1.4. "Business Entity" means anartificial legal entity, formed to conduct one ormore ventures for profit, or not for profit, that isduly authorized and empowered to sue and besued, and to hold the title to property, in its ownname.

1.1.1.5. "Category 1(c) Lands" meanslands selected by the State and not tentativelyapproved and not withdrawn under section11(a)(2) of the Alaska Native Claims SettlementAct.

1.1.1.6. "Category 1(d) Lands" meanslands selected by the State and not tentativelyapproved and which were withdrawn undersection 11(a) (2) of the Alaska Native ClaimsSettlement Act but which are not available forvillage or regional selection under section 22(1)of the Alaska Native Claims Settlement Act, 85Stat. 713, 43 U.S.C. § 1621 (1970).

1.1.1.7. "Commissioning" means theacceptance and custody by Permittees of thefirst Oil tendered for shipment through thePipeline after provision for line fill and tankbottoms. Permittees shall, by written notice,promptly advise the Authorized Officer of thedate upon which such acceptance and custodytakes place.

1.1.1.8. "Construction Mode� means thetype of construction to be employed generallywith regard to the Pipeline (E.g., whether thepipe will be buried or elevated).

1.1.1.9. �Construction Segment" means aportion of the Pipeline System that constitutes acomplete physical entity or stage, in and of itself,which can be constructed, independently of anyother portion or stage of the Pipeline System, ina designated area or between two givengeographical points reasonably proximate to oneanother. It is not to be construed as referring tothe entirety of the Pipeline or of the PipelineSystem.

1.1.1.10. "Construction Subdivision"means any one of approximately six (6) large,lineal sections of the route of the Pipeline asdetermined by the Authorized Officer afterconsulting with Permittees.

1.1.1.11. "Department" means theDepartment of the Interior of the United States,or any successor department or agency.

1.1.1.12. "Final Design" comprisescompleted design documents. It shall includecontract plans and specifications; proposedConstruction Modes; operational requirementsnecessary to justify designs; schedules; designanalysis (including sample calculations for eachparticular design feature); all functional andengineering criteria; summaries of testsconducted and their results; and other

APPENDIX F

D-3

considerations pertinent to design and projectlife expectancy.

1.1.1.13. "Involuntary Passage of Title"means a Transfer that is made by the exercise ofa power of sale primarily for the benefit ofcreditors, or in accordance with the judgment,order or decree of a court in bankruptcy, eminentdomain or other similar proceedings, or pursuantto any act or resolution of a sovereign legislativebody directing a lawful taking of property.

1.1.1.14. "Mapping Segment" means aConstruction Subdivision, or any part thereof, asdetermined by the Authorized Officer; provided,however, that with respect to a pump station,basic communication site, remote control valvesite, mechanical refrigeration equipment site andany other like Related Facility, a MappingSegment means the entire site.

1.1.1.15. "Notice to Proceed" means apermission to initiate Pipeline Systemconstruction that is issued in accordance withStipulation 1.7.

1.1.1.16. "Oil" means unrefined liquidhydrocarbons, including gas liquids.

1.1.1.17. "Parent" means a Person orBusiness Entity whose direct or indirect legal orbeneficial ownership interest in, or with respectto, a Transferee or Permittee enables thatPerson or Business Entity to control theTransferee's or the Permittee's management orpolicies.

1.1.1.18. "Permittee� means any one ofthe Permittees.

1.1.1.19. "Permittees" means the OriginalPermittees, or their respective successors orassigns holding an undivided ownership interestin the Right-of-Way to the extent sanctioned bythe Secretary in accordance with the provisionsof this Agreement.

1.1.1.20. "Person" means a naturalperson.

1.1.1.21. "Persons" means more thanone Person.

1.1.1.22. "Pipeline System" means allfacilities located in Alaska used by Permittees in

connection with the construction, operation,maintenance or termination of the Pipeline. Thisincludes, but is not limited to, the Pipeline,storage tanks, Access Roads, communicationssites, airfields, construction camps, materialssites, bridges, construction equipment andfacilities at the origin station and at the Valdezterminal. This does not include facilities used inconnection with production of oil or gatheringsystems, nor does it include such things asurban administrative offices and similar facilities,which are only indirectly involved.

1.1.1.23. "Preliminary Design" means theestablishment of project criteria (i.e.,construction, including design, and operationalconcepts) necessary to delineate the project tobe constructed. As a minimum it includes thefollowing: design criteria and project concepts;evaluation of field data used to establish thedesign criteria; drawings showing functional andtechnical requirements; reports of all test datacompiled during the data collection andpreliminary design evaluation; standarddrawings (if applicable) or drawings to supportstructural design concepts of each typical facilityor structure; proposed Construction Modes;outline project specifications; samplecomputations to support the design conceptsand bases for project siting.

1.1.1.24. A. "Related Facilities� meansthose structures, devices, improvements, andsites, the substantially continuous use of whichis necessary for the operation or maintenance ofthe Oil transportation pipeline, including:

(1) line pipe and supporting structures;

(2) pump stations, including associatedbuildings, heliports, structures, yardsand fences;

(3) valves and other control devices, andstructures housing them;

(4) monitoring and communication devices,and structures housing them;

(5) surge and storage tanks, and relatedcontainment structures;

(6) bridges;

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(7) terminals, including associatedbuildings, heliports, structures, yards,docks, and fences;

(8) a gas fuel line and electrical power linesnecessary to serve the Pipeline;

(9) retaining wills, berms, dikes, ditches,cuts and fills, including hydraulic controlstructures;

(10) storage buildings and structures, andareas for storage of supplies andequipment;

(11) administrative buildings;

(12) cathodic protection devices;

(13) mechanical refrigeration equipment;and

(14) such other facilities as the AuthorizedOfficer shall determine to be RelatedFacilities

B. "Related Facilities" not authorized bythis Agreement include roads and airports.Authorizations for such Related Facilities shallbe given by other instruments.

C. �Related Facilities� does not mean thosestructures, devices, improvements, sites,facilities or areas, the use of which is temporaryin nature such as those used only forconstruction purposes. Among such are:temporary camps; temporary landing strips;temporary bridges; temporary Access Roads;temporary communications sites; temporarystorage sites; disposal sites; and constructionuse areas.

1.1.1.25. "Secretary" means theSecretary of the Interior of the United States, hisdelegate or lawful successor.

1.1.1.26. "Secretary of Labor" means theSecretary of Labor of the United States, hisdelegate or lawful successor.

1.1.1.27. "Subsidiary" means a BusinessEntity, that may or may not be a Permittee; themanagement and policies of which arecontrolled by a Parent directly or indirectlythrough one or more intermediaries.

1.1.1.28. "Transfer� means the passageof any right, title or interest in property (real,personal or mixed) by sale, grant, assignment,operation of law or otherwise, and whethervoluntary or not.

1.1.1.29. "Transferee" means anyPerson, Business Entity or governmental orquasi-governmental body or authority in whichthere is, or there is proposed to be, vested anyright, title, or interest of a Permittee in theAgreement or the Right-of-Way pursuant to aTransfer.

1.1.1.30. �Transferor" means anyPermittee that makes, or that seeks to make, aTransfer of any right, title or interest in thisAgreement or the Right-of-Way.

1.1.2. Terms Defined Elsewhere inThis Agreement:

Term Page1. Agreement ........................................... 12. District Engineer .................................. B-33. Effective Date ...................................... 14. Federal Lands...................................... 25. Fish Spawning Beds ............................ D-146. Installation Commander....................... B-37 Oil Spill Control ................................... D-168. Operating Agreement .......................... 279. Operational Design Level .................... D-1910. Original Permittees .............................. 111. Ownership Agreements ....................... 2712. Pipeline ................................................ 313. Put-to-Bed............................................ D-1014. Right-of-Way........................................ 215. Segregated Facilities ........................... E-816. Standard Project Flood ........................ D-2017. Standdown Period................................ 1718. Stipulations .......................................... 319. Thaw Stable Sand and Gravel ............. D-1820. Use Charge.......................................... 521. Vessel .................................................. 1522. Waste................................................... D-13

1.2. Responsibilities

1.2.1. Except where the approval of theAuthorized Officer is required before Permitteesmay commence a particular operation, neitherthe United States nor any of its agents oremployees agrees, or is in any way obligated, toexamine or review any plan, design,

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specification, or other document which may befiled with the Authorized Officer by Permitteespursuant to these Stipulations.

1.2.2. The absence of any comment bythe Authorized Officer or any other agent oremployee or contractor of the United States withrespect to any plan, design, specification, orother document which may be filed byPermittees with the Authorized Officer shall notbe deemed to represent in any way whateverany assent to, approval of, or concurrence insuch plan, design, specification, or otherdocument or of any action proposed therein.

1.2.3. With regard to the construction,operation, maintenance and termination of thePipeline System: (1) Permittees shall ensure fullcompliance with the provisions of thisAgreement, including these Stipulations, by theiragents, employees and contractors (includingsubcontractors of any tier), and the employees ofeach of them. (2) Unless clearly inapplicable,the requirements and prohibitions imposed uponPermittees by these Stipulations are alsoimposed upon each Permittee's agents,employees, contractors, and subcontractors, andthe employees of each of them. (3) Failure orrefusal of a Permittees's agents, employees,contractors, subcontractors, or their employeesto comply with these Stipulations shall bedeemed to be the failure or refusal of thePermittee. (4) Each Permittee shall require itsagents, contractors and subcontractors toinclude these Stipulations in all contracts andsubcontracts which are entered into by any ofthem, together with a provision that the othercontracting party, together with its agents,employees, contractors and subcontractors, andthe employees of each of them, shall likewise bebound to comply with these Stipulations.

1.2.4. Permittees shall make separateapplication, under applicable statutes andregulations, for authorization to use or occupyFederal Lands in connection with the PipelineSystem where the lands are not within the Right-of-Way granted by this Agreement.

1.3 Authorized Officer

1.3.1. For purposes of information andreview, the Authorized Officer may call uponPermittees at any time to furnish any or all data

related to construction, operation, maintenanceand termination activities undertaken inconnection with the Pipeline System.

1.3.2. The Authorized Officer may requirePermittees to make such modification of thePipeline System, without liability or expense tothe United States, as he deems necessary to:protect or maintain stability of geologicmaterials; protect or maintain integrity of thePipeline System; prevent serious and irreparableharm to the environment (including but notlimited to fish or wildlife populations, or theirhabitats); or remove hazards to public health andsafety.

1.4. Common Agent of Permittees

1.4.1. Permittees, and each of them, haveappointed Alyeska Pipeline Service Company astheir common agent to design and construct thePipeline System under and pursuant to anagreement entitled "Agreement for the Designand Construction of the Trans Alaska PipelineSystem," dated August 27, 1970, and intend toappoint Alyeska Pipeline Service Company astheir common agent to operate, maintain andterminate the Pipeline System under andgenerally pursuant to an Operating Agreementreferred to in Section 5.1 of the "Trans AlaskaPipeline System Agreement," dated August 27,1970. A Power of Attorney has been filed withthe Department of the Interior by each Permitteeappointing Alyeska Pipeline Service Companythe true and lawful agent and attorney-in-fact onbehalf of each Permittee with full power andauthority to execute and deliver any and allinstruments in connection with the design,construction, or operation of the PipelineSystem. Within the scope of such contractualauthority, such agent shall represent Permittees,and each of them, with respect to thisAgreement. Such agent is and shall beempowered on behalf of Permittees, and each ofthem, to accept service of any process,pleadings or other documents in connection withany court or administrative proceeding relating inwhole or in part to this Agreement or to all or anypart of the Pipeline System and to which theUnited States shall be a party.

1.4.2. Permittees shall maintain acommon agent for the construction, operation,maintenance and termination of the Pipeline

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System at all times during this Agreement. Suchagent shall be a citizen of the United States, or ifa corporation, a domestic corporation. Suchagent shall be a resident of Alaska, or if acorporation, shall be duly authorized to conductbusiness in Alaska. Permittees shall cause suchagent to maintain in the City of Anchorage,Alaska, at all times during this Agreement anoffice for the delivery of all documents, orders,notices and other written communications, asprovided for in Stipulations 1.4.1. and 1.6.

1.4.3. In the event Permittees substitute anew common agent at any time, Permittees shallgive prompt written notice to the AuthorizedOfficer of such substitution, the name and officeaddress in Anchorage, Alaska, of the new agent,and a copy of Permittees' agreement with thenew agent. The United States shall be entitledto rely on each appointment until such time as anotice of the substitution of a new common agenttakes effect. Each such notice shall not takeeffect until two (2) full working days after (andnot including) the date that it was received by theAuthorized Officer.

1.4.4. Upon the Transfer by any Permitteeof any right, title or interest of Permittee in theRight-of-Way or this Agreement, the Transfereeshall promptly execute and deliver to theAuthorized Officer such documents as may berequired to evidence the Transferee'sappointment and ratification of the then-actingcommon agent.

1.5. Authority of Representativesof Authorized Officer and CommonAgent; Orders of Authorized Officer

1.5.1. No order or notice given toPermittees on behalf of the Secretary by theAuthorized Officer or any other Person shall beeffective as to Permittees unless prior writtennotice of the delegation of authority to issue suchorder or notice has been given to Permittees inthe manner provided in Stipulation 1.6.

1.5.2. Permittees shall comply with eachand every lawful order directed to them and thatis issued by the Secretary, the Authorized Officeror by any duly authorized representative of theAuthorized Officer.

1.5.3. Permittees shall cause the commonagent of Permittees to maintain a sufficientnumber of its duly authorized representatives toallow for the prompt delivery to Permittees, orany of them, of all notices, orders and othercommunications, written or oral, of the Secretaryor Authorized Officer. Each of the saidrepresentatives shall be registered with theAuthorized Officer, and shall be appropriatelyidentified in such manner and on such terms asthe Authorized Officer shall prescribe.Permittees shall cause the common agent ofPermittees to consult with the Authorized Officerat any time regarding the number and location ofsuch representatives of the common agent.

1.6. Orders and Notices

1.6.1. All decisions, determinations,authorizations, approvals, consents, demands ordirections that shall be made or given by theSecretary or the Authorized Officer to any one ormore of Permittees in connection with theenforcement or administration of this Agreement,any applicable law or regulation, or any otheragreement, permit or authorization relating inwhole or in part to all or any part of the PipelineSystem shall, except as otherwise provided inStipulation 1.6.2. of this Stipulation, be in theform of a written order or notice.

1.6.2. If, in the judgment of the Secretaryor the Authorized Officer, there is an emergencythat necessitates the immediate issuance to anyone or more of Permittees of an order or notice,such order or notice may be given orally,provided, however, that subsequent confirmationof the order or notice shall be given in writing asrapidly as is practicable under thecircumstances.

1.6.3. All written orders, notices or otherwritten communications, including telegrams,relating to any subject (and regardless ofwhether they do or do not relate to the design orconstruction of the Pipeline System) that areaddressed to any one or more of Permitteesshall be deemed to have been delivered to andreceived by the addressee or addressees whenthe order, notice or other communication hasbeen delivered: (1) either by messenger duringnormal business hours or by means of registeredor certified United States mail, postage prepaid,return receipt requested, to the office of the

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common agent of Permittees at 1815 SouthBragaw Street, Anchorage, Alaska 99504, or(2) personally to any authorized representativeof the common agent.

1.6.4. All written notices andcommunications, including telegrams, of any oneor more of Permittees that are addressed to theSecretary shall be deemed to have beendelivered to and received by the Secretary whenthe notice or communication has been delivered,either by messenger during normal businesshours or by means of registered or certifiedUnited States mail, postage prepaid, returnreceipt requested, to the Secretary personally orto Office Room No. 6151 in the Department ofthe Interior Building, 18th & C Streets,Northwest, Washington, D.C. 20240.

1.6.5. All written notices andcommunications of any one or more ofPermittees that are addressed to the AuthorizedOfficer shall be deemed to have been deliveredand received by the addressee when the noticeor communication has been delivered, either bymessenger during normal business hours or bymeans of registered or certified United Statesmail, postage prepaid, return receipt requested,to the Authorized Officer personally or to OfficeRoom No. 405, 555 Cordova Street, Anchorage,Alaska 99504.

1.6.6. The United States or Permittees, bywritten notice to the other, may change the officeaddress to which written notices, orders, or otherwritten communications may be addressed anddelivered thereafter, subject, however, to theprovisions of Stipulation 1.4.

1.6.7. The regulations of the Departmentrelating to notices or other communications bymail (43 CFR 1810.2) shall not be applicable tothis Agreement.

1.7. Notices To Proceed

1.7.1. Permission to Construct

1.7.1.1. Permittees shall not initiate anyconstruction of the Pipeline System without priorwritten permission of the Authorized Officer.Such permission shall be given solely by meansof a written Notice to Proceed issued by theAuthorized Officer. Each Notice to Proceed shall

authorize construction only as therein expresslystated and only for the particular ConstructionSegment therein described.

1.7.1.2. The Authorized Officer shallissue a Notice to Proceed only when in hisjudgment the construction (including design) andoperation proposals are in conformity with theprovisions of these Stipulations.

1.7.1.3. By written notice, the AuthorizedOfficer may revoke in whole or in part any Noticeto Proceed which has been issued when in hisjudgment unforeseen conditions later arisingrequire alterations in the Notice to Proceed inorder to: protect or maintain stability of geologicmaterials; protect or maintain integrity of thePipeline System; prevent serious and irreparableharm to the environment (including but notlimited to fish or wildlife populations, or theirhabitats); or remove hazards to public health andsafety.

1.7.1.4. Prior to submission of anyPreliminary Designs or applications for anyNotice to Proceed, Permittees and theAuthorized Officer shall agree to a schedule forthe time, scope and quantity of suchsubmissions and applications. The purpose ofsuch schedule is to assure that Permittees'submissions and applications shall bereasonable in scope, and filed in a reasonabletime frame, insofar as the workload therebyimposed on the Authorized Officer is concerned.Submittals and applications shall be filed inaccordance with said schedule, and theAuthorized Officer may refuse to consider anythat are not so filed. The schedule may bereviewed and revised from time to time as maybe agreed upon by Permittees and AuthorizedOfficer.

1.7.2. Preliminary DesignSubmissions

1.7.2.1. Prior to applying for a Notice toProceed for any Construction Segment,Permittees shall submit the Preliminary Designfor that Segment to the Authorized Officer forapproval. Where appropriate, each submissionshall include the criteria which justify theselection of the Construction Modes. TheAuthorized Officer shall expeditiously revieweach submission and shall do so within thirty

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(30) days from the date of his receipt of thesubmission. The Authorized Officer may requestadditional information if he deems it necessary.

1.7.2.2. In appropriate cases, theAuthorized Officer may waive the requirementthat a Preliminary Design be submitted. In thiscircumstance, Permittees may proceed to applyfor a Notice to Proceed in accordance withStipulation 1.7.4.

1.7.3. Summary Network AnalysisDiagram

1.7.3.1. Prior to Final Designsubmissions, Permittees shall submit a summarynetwork analysis diagram for the entire project tothe Authorized Officer. The summary networkanalysis diagram shall be time-scaled and shallinclude all activities and contingencies whichmay reasonably be anticipated in connectionwith the project. The summary network analysisdiagram shall include:

(1) Data collection activities;

(2) Submittal and approval activities;

(3) Pre-construction, construction and post-construction activities; and

(4) Other pertinent data.

1.7.3.2. The summary network analysisdiagram shall be updated at thirty (30) dayintervals, as significant changes occur, or asotherwise approved in writing by the AuthorizedOfficer.

1.7.4. Application for Notice toProceed

1.7.4.1. Permittees may apply for aNotice to Proceed for only those ConstructionSegments for which the Preliminary Design hasbeen approved in writing by the AuthorizedOfficer or a waiver pursuant to Stipulation 1.7.2.2has been issued in writing by the AuthorizedOfficer.

1.7.4.2. Before applying for a Notice toProceed for a Construction Segment, Permitteesshall, in such manner as shall be acceptable tothe Authorized Officer, by survey, locate andclearly mark on the ground the proposed

centerline of the line pipe to be located in theMapping Segment within which the ConstructionSegment is to be constructed and the location ofall Related Facilities proposed to be constructedin the Mapping Segment.

1.7.4.3. Each application for a Notice toProceed shall be supported by:

(1) A Final Design.

(2) All reports and results of environmentalstudies conducted or considered byPermittees.

(3) All data necessary to demonstratecompliance with the terms andconditions of these Stipulations withrespect to that particular ConstructionSegment.

(4) A detailed network analysis diagram forthe Construction Segment, including:Permittees' work schedules; consents,permits or authorizations required byState and Federal agencies and theirinterrelationships; design and reviewperiods; data collection activities; andconstruction sequencing. The detailednetwork analysis diagram shall beupdated as required to reflect currentstatus of the project.

(5) A map or maps, prepared in suchmanner as shall be acceptable to theAuthorized Officer, depicting theproposed location in the MappingSegment within which the ConstructionSegment is to be constructed of: (1) theboundaries of all contiguous temporaryuse areas, and (2) all improvements,buried or aboveground, that are to beconstructed within the MappingSegment. The Authorized Officer shallnot issue a Notice to Proceed withconstruction until he has approved allrelevant locations on the ground andtemporary boundary markers have beenset by Permittees to the satisfaction ofthe Authorized Officer.

(6) Such other data as may be requested bythe Authorized Officer either beforesubmission of the application for a

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Notice to Proceed or at any time duringthe review period.

1.7.4.4. During review of an applicationfor a Notice to Proceed, the relevant portion ofthe route of the Pipeline may be modified by theAuthorized Officer, if, in his judgment,environmental conditions or new technologicaldevelopments warrant the modifications. If,during construction, adverse physical conditionsare encountered that were not known to exist, orthat were known to exist but their significancewas not fully appreciated when the AuthorizedOfficer issued a Notice to Proceed for the portionof the Mapping Segment in which the physicalconditions are encountered, the AuthorizedOfficer may authorize deviations from the initiallyapproved location of the Pipeline to anotherlocation along the same general route of thePipeline at the point or points where the physicalconditions are encountered, including adequateroom for structurally sound transition. Adeviation shall not be constructed without theprior written approval of the Authorized Officerand, if so approved, shall conform in all respectsto the provisions of the approval.

1.7.4.5. The Authorized Officer shallreview each application for a Notice to Proceedand all data submitted in connection therewithwithin ninety (90) days. Said ninety (90) dayperiod shall begin from the later of the followingdates:

(1) Date of receipt by the Authorized Officerof an application for a Notice to Proceed.

(2) Date of receipt by the Authorized Officerof the last submittal of additional datapursuant to this Stipulation.

1.7.4.6. If the Authorized Officer requiresPermittees to submit additional data on one ormore occasions, the review period shall beginfrom the date of receipt by the Authorized Officerof the last submittal.

1.8. Changes in Conditions

1.8.1. Unforeseen conditions arisingduring construction, operation, maintenance ortermination of the Pipeline System may make itnecessary to revise or amend these Stipulationsto control or prevent damage to the environment

or hazards to public health and safety. In thatevent, Permittees and the Authorized Officershall agree as to what revisions or amendmentsshall be made. If they are unable to agree, theSecretary shall have final authority to determinethe matter.

1.9. Antiquities and HistoricalSites

1.9.1. Permittees shall engage anarcheologist approved by the Authorized Officerto provide surveillance and inspection of thePipeline System for archeological values.

1.9.2. If, in connection with any operationunder this Agreement, or any other Agreementissued in connection with the Pipeline System,Permittees encounter known or previouslyunknown paleontological, archeological, orhistorical sites, Permittees shall immediatelynotify the Authorized Officer and saidarcheologist. Permittees' archeologist shallinvestigate and provide an on the-ground opinionregarding the protection measures to beundertaken by Permittees. The AuthorizedOfficer may suspend that portion of Permittees'operations necessary to preserve evidencepending investigation of the site.

1.9.3. Six copies of all survey andexcavation reports shall be filed with theAuthorized Officer.

1.10. Completion of Use

1.10.1. Upon completion of the use of all,or a very substantial part, of the Right-of-Way orother portion of the Pipeline System, Permitteesshall promptly remove all improvements andequipment, except as otherwise approved inwriting by the Authorized Officer, and shallrestore the land to a condition that is satisfactoryto the Authorized Officer or at the option ofPermittees pay the cost of such removal andrestoration. The satisfaction of the AuthorizedOfficer shall be stated in writing. Whereapproved in writing by the Authorized Officer,buried pipe may be left in place, provided all oiland residue are removed from the pipe and theends are suitably capped.

1.10.2. All areas that do not constitute all,or a very substantial part of the Right-of-Way or

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other portion of the Pipeline System, utilizedpursuant to authorizations issued in connectionwith the Pipeline System, shall be Put-to-Bed byPermittees upon completion of their use unlessotherwise directed by the Authorized Officer.Put-to-Bed is used herein to mean that AccessRoads, material sites and other areas shall beleft in such stabilized condition that erosion willbe minimized through the use of adequatelydesigned and constructed waterbars,revegetation and chemical surface control; thatculverts and bridges shall be removed byPermittees in a manner satisfactory to theAuthorized Officer, and that such roads, sitesand areas shall be closed to use. Permittees'rehabilitation plans shall be approved in writingby the Authorized Officer prior to termination ofuse of any such road, or any part thereof, inaccordance with Stipulation 2.12.

1.11. Public Improvements

1.11.1. Permittees shall protect existingtelephone, telegraph and transmission lines,roads, trails, fences, ditches and likeimprovements during construction, operation,maintenance and termination of the PipelineSystem. Permittees shall not obstruct any roador trail with logs, slash, or debris. Damagecaused by Permittees to public utilities andimprovements shall be promptly repaired byPermittees to a condition which is satisfactory tothe Authorized Officer.

1.12. Regulation of Public Access

1.12.1. During construction or terminationactivities, Permittees may regulate or prohibitpublic access to or upon any Access Road beingused for such activity. At all other times,Permittees shall permit free and unrestrictedpublic access to and upon Access Roads,except that with the written consent of theAuthorized Officer, Permittees may regulate orprohibit public access and vehicular traffic onAccess Roads as required to facilitateoperations or to protect the public, wildlife andlivestock from hazards associated with operationand maintenance of the Pipeline System.Permittees shall provide appropriate warnings,flagmen, barricades, and other safety measureswhen Permittees are using Access Roads, orregulating or prohibiting public access to or uponAccess Roads.

1.12.2. During construction of the PipelineSystem, Permittees shall provide alternativeroutes for existing roads and trails as determinedby the Authorized Officer whether or not theseroads or trails are recorded.

1.12.3. Permittees shall make provisionsfor suitable permanent crossings for the publicwhere the Right-of-Way or Access Roads crossexisting roads, foot-trails, winter trails, or otherrights-of-way.

1.12.4. After completion of construction ofthe Pipeline System, and with the concurrence ofPermittee, the Authorized Officer may designateareas of the Right-of-Way to which the publicshall have free and unrestricted access. Certainareas of the Right-of-Way and conditions foraccess were published in a notice in the FederalRegister on May 16, 1983, p. 22001, and are stillin effect.

1.13. Electronically OperatedDevices

1.13.1. Permittee shall screen, filter, orotherwise suppress any electronically operateddevices that are installed as part of the PipelineSystem which are capable of producingelectromagnetic interference radiations so thatsuch devices will not adversely affect thefunctioning of existing communications systemsor navigational aids. In the event that structuressuch as towers or buildings are to be erected asa part of the Pipeline System, their positioningshall be such that they will not obstruct radiationpatterns of line-of-sight communicationssystems, navigational aids, or similar systems.

1.14. Camping, Hunting, Fishingand Trapping

1.14.1. Permittees shall post the Right-of-Way against camping, hunting, fishing, trappingand shooting within the Right-of-Way.Permittees shall prohibit their employees,agents, contractors, subcontractors, and theiremployees, from engaging in such activities.

1.14.2. Permittees shall inform theiremployees, agents, contractors, subcontractors,and their employees, of applicable laws andregulations relating to hunting, fishing, andtrapping.

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1.15. Small Craft Passage

1.15.1. The creation of any permanentobstruction to the passage of small craft instreams is prohibited.

1.16. Protection of SurveyMonuments

1.16.1. Permittees shall mark and protectall geodetic survey monuments encounteredduring the construction, operation, maintenanceand termination of the Pipeline System. Thesemonuments are not to be disturbed; however, ifsuch a disturbance occurs, the AuthorizedOfficer shall be immediately notified thereof inwriting.

1.16.2. If any land survey monuments,corners, or accessories (excluding geodeticsurvey monuments) are destroyed, obliterated ordamaged, Permittees shall employ a qualifiedland surveyor to reestablish or restore same inaccordance with the "Manual of Instruction forthe Survey of Public Lands" and shall recordsuch survey in the appropriate records.Additional requirements for the protection ofmonuments, corners, and bearing trees may beprescribed by the Authorized Officer.

1.17. Fire Prevention andSuppression

1.17.1. Permittees shall promptly notifythe Authorized Officer and take all measuresnecessary or appropriate for the prevention andsuppression of fires in accordance with43 CFR 2801.1-5(d). Permittees shall complywith the instructions and directions of theAuthorized Officer concerning the use,prevention and suppression of fires. Use ofopen fires in connection with construction of thePipeline System is prohibited unless authorizedin writing by the Authorized Officer.

1.18. Surveillance andMaintenance

1.18.1 During the construction, operation,maintenance and termination of the PipelineSystem, Permittees shall conduct a surveillanceand maintenance program applicable to thesubarctic and arctic environment. This programshall be designed to: (1) provide for public health

and safety; (2) prevent damage to naturalresources; (3) prevent erosion; and (4) maintainPipeline System integrity.

l.18.2. Permittees shall have acommunication system that ensures thetransmission of information required for the safeoperation of the Pipeline System.

1.18.3. Permittees shall maintaincomplete and up-to-date records onconstruction, operation, maintenance andtermination activities performed in connectionwith the Pipeline System. Such records shallinclude surveillance data, leak and breakrecords, necessary operational data,modification records and such other data as theAuthorized Officer may require.

1.18.4. Permittees shall provide andmaintain Access Roads and airstrips, thenumber and location of which shall be approvedby the Authorized Officer, to ensure thatPermittees' maintenance crews and Federal andState representatives shall have continuingaccess to the Pipeline System.

1.19. Housing and Quarters

1.19.1. Permittees shall furnish, on areimbursable basis, such representatives of theUnited States as may be designated by theAuthorized Officer with adequate meals, livingquarters and office space, reasonable use ofPermittees' communications systems, andreasonable surface and air transportation duringthe construction, operation, maintenance andtermination of the Pipeline System. Wheneverpossible, Permittees shall be notified in writingby the Authorized Officer in advance regardingthe number of persons for whom such servicesand facilities will be required.

1.20. Health and Safety

1.20.1. Permittees shall take all measuresnecessary to protect the health and safety of allpersons affected by their activities performed inconnection with the construction, operation,maintenance or termination of the PipelineSystem, and shall immediately abate any healthor safety hazards. Permittees shall immediatelynotify the Authorized Officer of all serious

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accidents which occur in connection with suchactivities.

1.21. Conduct of Operations

1.21.1. Permittees shall perform allPipeline System operations in a safe andworkmanlike manner so as to ensure the safetyand integrity of the Pipeline System, and shall atall times employ and maintain personnel andequipment sufficient for that purpose.Permittees shall immediately notify theAuthorized Officer of any condition, problem,malfunction, or other occurrence which in anyway threatens the integrity of the PipelineSystem.

1.22. Applicability of Stipulations

1.22.1. Nothing in these Stipulations shallbe construed as applying to activities ofPermittees that have no relation to the PipelineSystem.

1.22.2. Nothing in these Stipulations shallbe construed to affect any right or cause ofaction that otherwise would be available toPermittees against any person other than theUnited States.

2. ENVIRONMENTAL

2.1. Environmental Briefing

2.1.1. Prior to, and during, construction ofthe Pipeline System, Permittees shall provide forenvironmental and other pertinent briefings forconstruction and other personnel by suchFederal employees as may be designated by theAuthorized Officer. Permittees shall arrange thetime, place and attendance for such briefingsupon request by the Authorized Officer.Permittees shall bear all costs of such briefingsother than salary, per diem, subsistence, andtravel costs of Federal employees. In addition,Permittees shall separately arrange with theState of Alaska for such similar briefings as theState may desire.

2.2. Pollution Control

2.2.1. General

2.2.1.1. Permittees shall conduct allactivities associated with the Pipeline System in

a manner that will avoid or minimize degradationof air, land and water quality. In theconstruction, operation, maintenance andtermination of the Pipeline System, Permitteesshall perform their activities in accordance withapplicable air and water quality standards,related facility siting standards, and relatedplans of implementation, including but not limitedto standards adopted pursuant to the Clean AirAct, as amended, 42 U.S.C. § 1857 et seq., andthe Federal Water Pollution Control Act, asamended, 33 U.S.C. § 1321 et seq.

2.2.2. Water and Land Pollution

2.2.2.1. Permittees shall comply withapplicable "Water Quality Standards" of theState of Alaska as approved by theEnvironmental Protection Agency.

2.2.2.2. Mobile ground equipment shallnot be operated in lakes, streams or riversunless such operation is approved in writing bythe Authorized Officer.

2.2.3. Thermal Pollution

2.2.3.1. Permittees shall comply with thestandards set for thermal pollution in the State ofAlaska "Water Quality Standards," as approvedby the Environmental Protection Agency.

2.2.4. Air Pollution and Ice Fog

2.2.4.1. Permittees shall utilize andoperate all facilities and devices used inconnection with the Pipeline System so as toavoid or minimize air pollution and ice fog.Facilities and devices which cannot beprevented from producing ice fog shall belocated so as not to interfere with airfields,communities or roads.

2.2.4.2. Emissions from equipment,installations and burning materials shall meetapplicable Federal and State air qualitystandards.

2.2.5. Pesticides, Herbicides andother Chemicals

2.2.5.l. Permittees shall use only non-persistent and immobile types of pesticides,herbicides and other chemicals. Each chemicalto be used and its application constraint shall be

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D-13

approved in writing by the Authorized Officerprior to use.

2.2.6. Sanitation and WasteDisposal

2.2.6.1. "Waste" means all discardedmatter, including but not limited to human waste,trash, garbage, refuse, oil drums, petroleumproducts, ashes and equipment.

2.2.6.2. All waste generated inconstruction, operation, maintenance andtermination of the Pipeline System shall beremoved or otherwise disposed of in a manneracceptable to the Authorized Officer. Allapplicable standards and guidelines of theAlaska State Department of EnvironmentalConservation, the United States Public HealthService, the Environmental Protection Agency,and other Federal and State agencies shall beadhered to by Permittees. All incinerators shallmeet the requirements of applicable Federal andState laws and regulations and shall be usedwith maximum precautions to prevent forest andtundra fires. After incineration, material notconsumed in the incinerator shall be disposed ofin a manner approved in writing by theAuthorized Officer. Portable or permanent wastedisposal systems to be used shall be approvedin writing by the Authorized Officer.

2.3. Buffer Strips

2.3.1. Public Interest Areas

2.3.1.1. No construction activity inconnection with the Pipeline System shall beconducted within one-half (½) mile of anyofficially designated Federal, State or municipalpark, wildlife refuge, research natural area,recreation area, recreation site, or any registeredNational Historic Site or National Landmark,unless such activity is approved in writing by theAuthorized Officer.

2.3.2. Vegetative Screen

2.3.2.1. Permittees shall not cut orremove any vegetative cover within a minimumfive hundred (500) foot strip between Statehighways and material sites unless such cuttingor removal is approved in writing by theAuthorized Officer.

2.3.2.2. Where the Right-of-way crossesState highways, a screen of vegetation native tothe specific setting shall be established overdisturbed areas unless otherwise approved inwriting by the Authorized Officer.

2.3.3. Streams

2.3.3.1. The Pipeline System shall belocated so as to provide three hundred (300) footminimum buffer strips of undisturbed land alongstreams unless otherwise approved in writing bythe Authorized Officer.

2.4. Erosion Control

2.4.1. General

2.4.1.1. Permittees shall perform allPipeline System construction, operation,maintenance and termination activities so as toavoid or minimize disturbance to vegetation.

2.4.1.2. The design of the PipelineSystem shall provide for the construction ofcontrol facilities that will avoid or minimizeerosion.

2.4.1.3. The erosion control facilities shallbe constructed to avoid induced and acceleratederosion and to lessen the possibility of formingnew drainage channels resulting from PipelineSystem activities. The facilities shall bedesigned and operations conducted in such away as to avoid or minimize disturbance to thethermal regime.

2.4.2. Stabilization

2.4.2.1. Surface materials taken fromdisturbed areas shall be stockpiled and utilizedduring restoration unless otherwise approved inwriting by the Authorized Officer. Stabilizationpractices, as determined by the needs forspecific sites, shall include but shall not belimited to seeding, planting, mulching, and theplacement of mat binders, soil binders, rock orgravel blankets, or structures.

2.4.2.2. All disturbed areas shall be left ina stabilized condition satisfactory to theAuthorized Officer. Such satisfaction shall bestated in writing by the Authorized Officer.

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D-14

2.4.3. Crossing of Streams, Riversor Flood Plains

2.4.3.1. Permittees shall prevent orminimize erosion at stream and river crossingsand those parts of the Pipeline System withinflood plains, as defined in Stipulation 3.6.

2.4.3.2. Temporary access over streambanks shall be made through use of fill rampsrather than by cutting through stream banks,unless otherwise approved in writing by theAuthorized Officer. Permittees shall removesuch ramps upon termination of seasonal or finaluse. Ramp materials shall be disposed of in amanner approved in writing by the AuthorizedOfficer.

2.4.4. Seeding and Planting

2.4.4.1. Seeding and planting of disturbedareas shall be conducted as soon as practicableand, if necessary, shall be repeated untilvegetation is successful, unless otherwiseapproved in writing by the Authorized Officer. Allother restoration shall be completed as soon aspossiblE.

2.4.5. Excavated Material

2.4.5.1. Excavated material in excess ofthat required to backfill around any structure,including the pipe, shall be disposed of in amanner approved in writing by the AuthorizedOfficer.

2.5. Fish and Wildlife Protection

2.5.1. Passage of Fish

2.5.1.1. Permittees shall provide foruninterrupted movement and safe passage offish. Any artificial structure or any streamchannel change that would cause a blockage tofish shall be provided with a fish passagestructure or facility that meets all Federal andState requirements. The proposed design shallbe submitted to the Authorized Officer inaccordance with Stipulation 1.7.

2.5.1.2. Pump intakes shall be screenedto prevent harm to fish.

2.5.1.3. Abandoned water diversionstructures shall be plugged and stabilized toprevent trapping or stranding of fish.

2.5.1.4. If material sites are approvedadjacent to or in certain lakes, rivers, or streams,the Authorized Officer may require Permittees toconstruct levees, berms or other suitable meansto protect fish and fish passage and to preventsiltation of streams or lakes.

2.5.2. Fish Spawning Beds

2.5.2.1. "Fish Spawning Beds" means theareas where anadromous and resident fishdeposit their eggs.

2.5.2.2. Permittees shall avoid channelchanges in Fish Spawning Beds designated bythe Authorized Officer; however, where channelchanges cannot be avoided in such beds, newchannels shall be constructed according towritten standards supplied by the AuthorizedOfficer.

2.5.2.3. Fish Spawning Beds shall beprotected from sediment where soil material isexpected to be suspended in water as a result ofconstruction activities. Settling basins shall beconstructed to intercept silt before it reachesstreams or lakes.

2.5.2.4. Permittees shall comply with anyspecial requirements made by the AuthorizedOfficer for a stream system in order to protectFish Spawning Beds. Permittees shall repair alldamage to Fish Spawning Beds caused byconstruction, operation, maintenance ortermination of the Pipeline System.

2.5.3. Zones of RestrictedActivities

2.5.3.1. Permittees' activities inconnection with the Pipeline System in key fishand wildlife areas may be restricted by theAuthorized Officer during periods of fish andwildlife breeding, nesting, spawning, lambing orcalving activity and during major migrations offish and wildlife. The Authorized Officer shallgive Permittees written notice of such restrictiveaction. From time to time, the Authorized Officershall furnish Permittees a list of areas where

APPENDIX F

D-15

such actions may be required, together withanticipated dates of restriction.

2.5.4. Big Game Movements

2.5.4.1. Permittees shall construct andmaintain the Pipeline, both buried and aboveground sections, so as to assure free passageand movement of big game animals.

2.6. Materials Sites

2.6.1. Purchase of Materials

2.6.1.1. If Permittees require materialsfrom the public lands, Permittees shall makeapplication to purchase such materials inaccordance with 43 CFR, Part 3610. Permitteesshall submit a mining plan in accordance with43 CFR, Part 23. No materials may be removedby Permittees without the written approval of theAuthorized Officer.

2.6.1.2. Insofar as possible, use ofexisting materials sites will be authorized inpreference to new sites.

2.6.1.3. Gravel and other constructionmaterial shall not be taken from stream beds,river beds, lake shores or other outlets of lakes,unless the taking is approved in writing by theAuthorized Officer.

2.6.2. Layout of Materials Sites

2.6.2.1. Materials site boundaries shall beshaped in such a manner as to blend withsurrounding natural land patterns. Regardless ofthe layout of materials sites, primary emphasisshall be placed on prevention of soil erosion anddamage to vegetation.

2.7. Clearing

2.7.1. Boundaries

2.7.1.1. Permittees shall identifyapproved clearing boundaries on the ground foreach Construction Segment prior to beginningclearing operations. All timber and othervegetative material outside clearing boundariesand all blazed, painted or posted trees which areon or mark clearing boundaries are reservedfrom cutting and removal with the exception of

danger trees or snags designated as such by theAuthorized Officer.

2.7.2. Timber

2.7.2.1. Prior to initiating clearingoperations, Permittees shall notify theAuthorized Officer of the amount ofmerchantable timber, if any, which will be, cut,removed or destroyed in the construction andmaintenance of the Pipeline System, and shallpay the United States in advance of suchconstruction or maintenance activity, such sumof money as the Authorized Officer determinesto be the full stumpage value of the timber to becut, removed or destroyed.

2.7.2.2. All trees, snags, and other woodymaterial cut in connection with clearingoperations shall be cut so that the resultingstumps shall not be higher than six (6) inchesmeasured from the ground on the uphill side.

2.7.2.3. All trees, snags and other woodymaterial cut in connection with clearingoperations shall be felled into the area within theclearing boundaries and away from watercourses.

2.7.2.4. Hand clearing shall be used inareas where the Authorized Officer determinesthat use of heavy equipment would bedetrimental to existing conditions.

2.7.2.5. All debris resulting from clearingoperations and construction that may blockstream flow, delay fish passage, contribute toflood damage, or result in stream bed scour orerosion shall be removed.

2.7.2.6. Logs shall not be skidded oryarded across any stream without the writtenapproval of the Authorized Officer.

2.7.2.7. No log landing shall be locatedwithin three-hundred (300) feet of any watercourse.

2.7.2.8. All slash shall be disposed of inconstruction pads or Access Roads unlessotherwise directed in writing by the AuthorizedOfficer.

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D-16

2.8. Disturbance of Natural Water

2.8.1 All activities of Permittees inconnection with the Pipeline System that maycreate new lakes, drain existing lakes,significantly divert natural drainage, permanentlyalter stream hydraulics, or disturb significantareas of stream beds are prohibited unless suchactivities along with necessary mitigationmeasures are approved in writing by theAuthorized Officer.

2.9. Off Right-of-Way Traffic

2.9.1. Permittees shall not operate mobileground equipment off the Right-of-Way, AccessRoads, State highways, or authorized areas,unless approved in writing by the AuthorizedOfficer or when necessary to prevent harm toany Person.

2.10. Aesthetics

2.10.1. Permittees shall consideraesthetic values in planning, construction andoperation of the Pipeline System. Where theRight-of-Way crosses a State highway inforested terrain, the straight length of thePipeline Right-of-Way visible from the highwayshall not exceed six hundred (600) feet in length,unless otherwise approved in writing by theAuthorized Officer. The Authorized Officer mayimpose such other requirements as he deemsnecessary to protect aesthetic values.

2.11. Use of Explosives

2.11.1. Permittees shall submit a plan foruse of explosives, including but not limited toblasting techniques, to the Authorized Officer inaccordance with Stipulation 1.7.

2.11.2. No blasting shall be done underwater or within one quarter (1/4) mile of streamsor lakes without a permit from the AlaskaDepartment of Fish and Game, when such apermit is required by State law or regulation.

2.12. Restoration

2.12.1. Areas disturbed by Permitteesshall be restored by Permittees to thesatisfaction of the Authorized Officer as stated inwriting.

2.12.2. All cut and fill slopes shall be leftin a stable condition.

2.12.3. Materials from Access Roads,haul ramps, berms, dikes, and other earthenstructures shall be disposed of as directed inwriting by the Authorized Officer.

2.12.4. Vegetation, overburden and othermaterials removed during clearing operationsshall be disposed of by Permittees in a mannerapproved in writing by the Authorized Officer.

2.12.5. Upon completion of restoration,Permittees shall immediately remove allequipment and supplies from the site.

2.13. Reporting of Oil Discharges

2.13.1. A discharge of Oil by Permitteesinto or upon the navigable waters of the UnitedStates, adjoining shorelines, or into or upon thewaters of the contiguous zone in violation of theFederal Water Pollution Control Act, asamended, 33 U.S.C. § 1321 et seq. and theregulations issued thereunder, or in violation ofapplicable laws of the State of Alaska andregulations issued thereunder, is prohibited.Permittees shall give immediate notice of anysuch discharge to: (1) the Authorized Officer,and (2) such other Federal and State officials asare required by law to be given such notice.

2.13.2. Permittees shall give immediatenotice of any spill or leakage of Oil or otherpollutant from the Pipeline, the Valdez terminalfacility, or any storage facility to: (1) theAuthorized Officer; and (2) such other Federaland State officials as are required by law to begiven such notice. Any oral notice shall beconfirmed in writing as soon as possible.

2.14. Contingency Plans

2.14.1. It is the policy of the Departmentof the Interior that there should be no dischargeof Oil or other pollutant into or upon lands orwaters. Permittees must therefore recognizetheir prime responsibility for the protection of thepublic and environment from the effects ofspillage.

2.14.2. Permittees shall submit theircontingency plans to the Authorized Officer atleast one-hundred and eighty (180) days prior to

APPENDIX F

D-17

scheduled start-up. The plans shall conform tothis Stipulation and the National Oil HazardousSubstances Pollution Contingency Plan,36 F.R. 16215, August 20, 1971, and shall:(1) include provisions for Oil Spill Control1;(2) specify that the action agencies responsiblefor contingency plans in Alaska shall be amongthe first to be notified in the event of any PipelineSystem failure resulting in an Oil spill;(3) provide for immediate corrective actionincluding Oil Spill Control and restoration of theaffected resource; (4) provide that theAuthorized Officer shall approve any materials ordevices used for Oil Spill Control and shallapprove any disposal sites or techniquesselected to handle oily matter; and (5) includeseparate and specific techniques and schedulesfor cleanup of Oil spills on land, lakes, rivers andstreams, sea, and estuaries.

2.14.3. Prior to Pipeline start-up, suchplans shall be approved in writing by theAuthorized Officer, and Permittees shalldemonstrate their capability and readiness toexecute the plans. Permittees shall update asappropriate the plans and methods ofimplementation thereof, which shall be submittedannually to the Authorized Officer for his writtenapproval.

2.14.4. If during any phase of theconstruction, operation, maintenance ortermination of the Pipeline, any Oil or otherpollutant should be discharged from the PipelineSystem, the control and total removal, disposaland cleaning up of such Oil or other pollutant,wherever found, shall be the responsibility ofPermittees, regardless of fault. Upon failure ofPermittees to control, dispose of, or clean upsuch discharge, the Authorized Officer may takesuch measures as he deems necessary tocontrol and clean up the discharge at the fullexpense of Permittees. Such action by theAuthorized Officer shall not relieve Permittees ofany responsibility as provided herein.

1 As used in this Stipulation 2.14.2, Oil Spill

Control is defined as: (1) detection of the spill;(2) location of the spill; (3) confinement of the spill;and (4) cleanup of the spill.

3. TECHNICAL

3.1. General

3.1.1. The following standards shall becomplied with in design, construction, operationand termination of the Pipeline System.

3.2. Pipeline System Standards

3.2.1. General Standards

3.2.1.1. All design, material andconstruction, operation, maintenance andtermination practices employed in the PipelineSystem shall be in accordance with safe andproven engineering practice and shall meet orexceed the following standards:

(1) U.S.A. Standard Code for PressurePiping, ANSI B 31.4, "Liquid PetroleumTransportation Piping System."

(2) Department of TransportationRegulations, 49 CFR, Part 195,"Transportation of Liquids by Pipeline."

(3) ASME Gas Piping Standard Committee,15 Dec. 1970: "Guide for GasTransmission and Distribution PipingSystem.�

(4) Department of TransportationRegulations, 49 CFR, Part 192,"Transportation of Natural and OtherGas by Pipelines: Minimum FederalSafety Standards."

3.2.1.2. Requirements in addition to thoseset forth in the above minimum standards maybe imposed by the Authorized Officer asnecessary to reflect the impact of subarctic andarctic, environments. If any standard contains aprovision which is inconsistent with a provisionin another standard, the more stringent shallapply.

3.2.2. Special Standards

3.2.2.1. The design shall also provide forremotely controlled shutoff valves at each pumpstation; remotely controlled mainline blockvalves (intended to control spills); and additionalvalves located with the best judgment regarding

APPENDIX F

D-18

wildlife habitat, fish habitat, and potentiallyhazardous areas.

3.2.2.2. All practicable means shall beutilized to minimize injury to the ground organiclayer.

3.2.2.3. Radiographic inspection of allmain line girth welds and pressure testing of thePipeline shall be conducted by Permittees priorto placing the system in operation.

3.2.2.4. Permittees shall provide forcontinuous inspection of Pipeline Systemconstruction to ensure compliance with thedesign specifications and these Stipulations.

3.2.2.5. Welder qualification tests shall beby destructive means, except that operators ofautomatic welding equipment for girth welding oftank seams shall be tested by radiography inaccordance with ASME Boiler and PressureVessel Code, Section 9, Subsection Q-21 (b).

3.2.2.6. Lightning protection shall conformto the requirements of ANSI C5.1-1969,"Lightning Protection Code-1968.�

3.2.2.7.� Slopes with a grade greater than10% shall have a static factor of safety (DesignBasis Appendix A-3.1079, p. 4-18) no less than1.5 and a dynamic factor of safety (Design BasisAppendix A-3.1079, p. 4-18) no less than 1.0 orground displacement no greater than 5 inchesunless otherwise approved as a variance by theAuthorized Officer.

3.2.2.8.� The following operationsstandard shall apply to the Trans-AlaskaPipeline mainline 48-inch diameter pipe. Theintervention criteria used to determine whencorrective maintenance is required shall include:

If the pipe curvature increases more than20% as a result of pipe movement in comparisonto the 1992 NOWSCO Curvature Pig data andthe cumulative curvature is greater than 85%Critical Buckling Curvature, or

� Modification adopted pursuant to

Stipulation 3.2.1.2 per letter of February 7, 2001.

� Modification adopted pursuant toStipulation 3.2.1.2 per letter of June 29, 2001.

Deformation data showing the formation of a0.25-inch �waveform� or bulge indicating theonset of wrinkling combined with other evidenceshowing pipe instability shall require correctivemaintenance.

3.2.3. Standards for Access Roads

3.2.3.1. Design, materials andconstruction practices employed for AccessRoads shall be in accordance with safe andproven engineering practice and in accordancewith the principles of construction for secondaryroads for the subarctic and arctic environments.

3.2.3.2. Permittees shall submit a layoutof each proposed Access Road for approval bythe Authorized Officer in accordance withStipulation 1.7.

3.2.3.3. Access Roads shall beconstructed to widths suitable for safe operationof equipment at the travel speeds proposed byPermittees.

3.2.3.4. The maximum allowable gradeshall be 12 percent unless otherwise approved inwriting by the Authorized Officer.

3.3. Construction ModeRequirements

3.3.1. The selection of the ConstructionMode (elevated or buried) shall be governed bythe following criteria: (1) There shall be anunobstructed air space of at least two feetbetween the pipe and ground surface; or(2) There shall be no greater heat transfer fromthe pipe to the ground than results from the useof an unobstructed air space of at least two(2) feet between the pipe and ground surface; or(3) Below the level of the pipe axis the groundshall consist of competent bedrock, soil naturallydevoid of permafrost, or if frozen, of Thaw-StableSand and Gravel.2 Above the level of the pipe

2 Thaw-Stable Sand and Gravel is defined asmaterial meeting the following requirements:(a) Material lies within the classes GW, GP, SW, andSP, (Unified Soil Classification) but with up to 6% byweight passing the #200 U.S. standard sieve; if aninorganic granular soil contains more than 6% finesthan the #200 sieve, its thaw-stability must bejustified. (b) There is no excess (segregated ormassive) ice. (c) Thawing of the material in situ willnot result in excess pore-pressure.

APPENDIX F

D-19

axis other materials may be present but it mustbe shown that they will remain stable under allcredible conditions; or (4) Results of a detailedfield exploration program and analysis indicatethat pipe rupture and major terrain disruption willnot occur at any place from soil instability.Effects and their interaction, which are to beanalyzed on a mile by mile basis to justify theproposed Construction Mode, shall include butnot be limited to, thaw plug stability, differentialsettlement, seismic loading and weakening, andpossible movement resulting from slopeinstability.3

As a prerequisite for the use of this criterion,an acceptable comprehensive monitoringsystem of the Pipeline shall be developed whichwill include but not be limited to makingdeformation measurements sufficiently sensitiveand prompt to detect the approach to operationaltolerance limits (which shall be clearly specified)of the Pipeline; design specifications,operational requirements, and feasibility analysisof such monitoring system shall be submitted inaccordance with Stipulation 1.7. Such systemshall be operational prior to transmission of Oilthrough the Pipeline.

3.4. Earthquakes and FaultDisplacements

3.4.1. Earthquakes

3.4.1.1. The Pipeline System shall bedesigned, where technically feasible, byappropriate application of modern, state-of-the-art seismic design procedures to prevent any Oilleakage from the effects (including seismicshaking, ground deformation and earthquake-induced mass movements) of earthquakesdistributed along the route as follows:

3 Because of soil variability and/or unique

hydrologic conditions in active flood plains, some ofthe requirements of Stipulation 3.3.1 may not be metin those locations. In such cases proposed designsincluding special design and/or constructionprocedures where required by these conditions mustbe submitted with justification to the AuthorizedOfficer for approval in accordance withStipulations 1.7.

RichterZone: magnitude

Valdez to Willow Lake 8.5Willow Lake to Paxson 7.0Paxson to Donnelly Dome 8.0Donnelly Dome to 67 deg. N 7.567 deg. N. to Prudhoe Bay 5.5

3.4.1.2. Where such design is nottechnically feasible, the potential damage froman Oil spill shall be minimized by special designprovisions that shall include, but shall not belimited to: (1)a network of ground-motiondetectors that continuously monitor, record andinstantaneously signal the occurrence of groundmotion in the vicinity of the Pipeline reaching theOperational Design Level4 (the critical levels ofground motions shall be approved in writing bythe Authorized Officer); (2) rapid programmedshutdown and prompt close inspection of systemintegrity in the event of ground motion reachingthe Operational Design Level; and (3) a specialcontingency plan for Oil Spill Control for eachsuch seismically hazardous area which shall befiled in accordance with Stipulation 2.14. Thisplan shall specifically consider expected fieldconditions in the particular area in the aftermathof a destructive earthquake.

3.4.2. Fault Displacements

3.4.2.1. Prior to applying for a Notice toProceed for any Construction Segment,Permittees shall satisfy the Authorized Officerthat all recognizable or reasonably inferred faultsor fault zones along the alignment within thatsegment have been identified and delineated,and that the risk of Oil leakage resulting fromfault movement and ground deformation hasbeen adequately assessed and provide for in thedesign of the Pipeline for that segment.Evaluation of said risk shall be based ongeologic, geomorphic, geodetic, seismic, andother appropriate scientific evidence of past orpresent fault behavior and shall be compatiblewith the design earthquakes tabulated aboveand with observed relationships betweenearthquake magnitude and extent and amount ofdeformation and fault slip within the fault zone.

4 Highest level that would not produce general pipe

deformation sufficient to limit operations.

APPENDIX F

D-20

3.4.2.2. Minimum design criteria for asegment of the Pipeline traversing a fault zonethat is reasonably interpreted as active, shall be:(1) that the Pipeline resist failure resulting inleakage from two feet of horizontal and/orvertical displacement in the foundation materialanywhere within the fault zone; and (2) that nostorage tank or pump station be located withinthe fault zone.

3.4.2.3. Where the Pipeline crosses afault or lies within a fault zone that is reasonablyinterpreted as active, Permittees shall monitorcrustal deformation in the vicinity of the Pipeline.Such monitoring shall include annual geodeticobservation of permanent reference marksestablished on stable ground. Said referencemarks shall he positioned so as to form closedfigures and to provide for detection of relativehorizontal and vertical displacements as smallas 0.10 ft. across principal individual faults withinthe fault zone and to provide for monitoring ofcrustal strain with an absolute error of two partsper million within the fault zone. Further, whereannual slip on a fault exceeds 0.10 ft. for twosuccessive years, Permittees shall installrecording or telemetering slip-meters. Dataobtained from the monitoring shall be provided tothe Authorized Officer at specified regularintervals throughout the operational life of thePipeline. Said data shall be used by thePermittees to aid in the initiation of correctivemeasures to protect the Pipeline from failurecaused by tectonic deformation that would resultin leakage.

3.5. Slope Stability

3.5.1. Areas subject to mudflows,landslides. avalanches, rock falls and othertypes of mass movements shall be avoidedwhere practicable in locating the Pipeline.Where such avoidance is not practicable, thePipeline design, based upon detailed fieldinvestigations and analysis, shall providemeasures to prevent the occurrence of, orprotect the Pipeline against, the effects of massmovements.

3.6. Stream and Flood PlainCrossings and Erosion

3.6.1. General

3.6.1.1. For each region through whichthe Pipeline passes, the Pipeline shall bedesigned to withstand or accommodate theeffects (including runoff, stream and flood plainerosion, meander cutoffs, lateral migration, ice-jams, and icings) of those meteorologic,hydrologic (including surface and subsurface)and hydraulic conditions considered reasonablypossible for the region. The following standardsshall apply to such Pipeline design:

3.6.1.1.1. For stream crossings andportions of the Pipeline within the flood plain.

3.6.1.1.1.1. The Pipeline shall crossstreams underground unless a different meansof crossing is approved in writing by theAuthorized Officer.

3.6.1.1.1.2. The design flood shall bebased on the concept of the "Standard ProjectFlood" as defined in Corps of Engineers Bulletin52-8, Part 1.

3.6.1.1.1.3. The depth of channel scourshall be established by appropriate fieldinvestigations and theoretical calculations usingthose combinations of water velocity and depththat yield the maximum value. At the point ofmaximum scour, the cover over the pipe shall beat least twenty (20) percent of the computedscour, but not less than four (4) feet.

3.6.1.1.1.4. For overhead crossingscomparable analysis shall be made to ensurethat support structures are adequately protectedfrom the effects of scour, channel migration,undercutting, ice forces and degradation ofpermafrost.

3.6.1.1.1.5. In flood plains, appropriateconstruction procedures shall be used whereverthere is potential channelization along the pipe.

3.6.1.1.1.6. The pipe trench excavationshall stop an adequate distance from the watercrossing to leave a protective plug (unexcavatedmaterial) at each bank. These plugs shall be leftin place until the stream bed excavation iscomplete and the pipe laying operation is begun.

APPENDIX F

D-21

The plugs shall not be completely removed untilabsolutely necessary. The trench shall bebackfilled with stable material as soon as thepipe is laid.

3.6.1.2. Culverts and Bridges

3.6.1.2.l. Culverts and bridges necessaryfor maintenance of the Pipeline shall bedesigned to accommodate a fifty (50) -year floodin accordance with criteria established by theAmerican Association of State Highway Officialsand the Federal Highway Administration andendorsed by the State of Alaska Department ofHighways.

3.6.2. Erosion

3.6.2.1. Where necessary because ofoutfall erosion, stilling basins shall beconstructed at the outflow end of culverts. Toprevent erosion the pool sides shall be stabilizedby appropriate methods; eg., by the use ofriprap.

3.6.2.2. Slopes of cuts through streambanks shall be designed and constructed tominimize erosion and prevent slides.

3.6.2.3. Erosion control procedures shallaccommodate and be based on the runoffproduced by the maximum rainfall rate and snowmelt rate combination reasonably characteristicof the region. The procedures shall alsoaccommodate effects that result from thawingproduced by flowing or pond water on permafrostterrain.

3.7. Sea Waves

3.7.1. Oil transfer facilities at the Valdezterminal shall be protected by cut-off devicesdesigned and located to prevent major Oilleakage from breaking of pipes by destructivesea waves comparable to those generated inPort Valdez by the March 27, 1964 earthquake.Design for such protective features shall besubmitted in accordance with Stipulation 1.7.

3.8. Glacier Surges

3.8.1. Surveillance systems sufficient togive adequate warning of impending surges onany glacier that could damage the Pipeline shallbe instituted prior to transmission of Oil through

the pipe. Procedures for initiation and operationof such surveillance systems and protectiveprocedures in the event of such surges shall besubmitted in accordance with Stipulation 1.7.

3.9. Construction and Operation

3.9.1. All construction, operation,maintenance, and termination activities inconnection with the Pipeline System shall beconducted so as to avoid or minimize thermaland other environmental changes and to providemaximum protection to fish and wildlife and theirhabitat, and people. All working platforms, pads,fills and other surface modifications shall beplanned and executed in such a way that anyresulting degradation of permafrost will notjeopardize the Pipeline foundations.

3.9.2. Acceptable plans, procedures andquality controls that ensure compliance withStipulation 3.9.1 shall be submitted inaccordance with Stipulation 1.7.

3.9.3.# Where a critical hardwarecomponent or foundation condition is identifiedas being not in compliance with design criteria,appropriate engineering evaluation andmaintenance intervention shall occur within ayear of discovery, but no later than one yearafter discovery unless approved.

3.9.4* Changes or variances from standingaboveground system design or inservice criteriafor unusual or changing foundation conditionswill require approval by the Authorized Officer.

3.10. Pipeline Corrosion

3.10.1. Permittees shall provide detailedplans for corrosion resistant design and methodsfor early detection of corrosion. These shallinclude: (1) pipe material and weldingtechniques to be used and information on theirparticular suitability for the environmentinvolved; (2) details on the external pipeprotection to be provided (coating, wrapping,etc.), including information on variation of the

# Modification adopted pursuant to

Stipulation 3.2.1.2 per letter of June 29, 2001.

* Modification adopted pursuant toStipulation 3.2.1.2 per letter of June 29, 2001.

APPENDIX F

D-22

coating process to cope with variations inenvironmental factors along the Pipeline route;(3) plans for cathodic protection including detailsof impressed ground sources and controls toensure continuous maintenance of adequateprotection over the entire surface of thepipe;(4) details of plans for monitoring cathodicprotection current including spacing of currentmonitors; (5) provision for periodic intensivesurveys of trouble spots, regular preventivemaintenance surveys and special provisions forabnormal potential patterns resulting from thecrossing of the Pipeline by other pipelines orcables; and (6) information on precautions to betaken to prevent internal corrosion of thePipeline. Permittees shall also provide forperiodic internal pitting surveys by electro-magnetic or other means.

3.11. Containment of Oil Spills

3.11.1. Permittees shall provide Oil spillcontainment dikes or other structures around

storage tanks at pump stations and at the Valdezterminal. The volume of the containmentstructures shall be at least: (1) one-hundred ten(110) percent of the total storage volume of thestorage tanks in the relevant area, plus (2) avolume sufficient for maximum trappedprecipitation and runoff which might beimpounded at the time of the spill. Suchstructures shall be constructed to withstandfailure from earthquakes in accordance withStipulation 3.4 and shall be impervious so as toprovide seepage-free storage until disposal oftheir contents can be effected safely withoutcontamination of the surrounding area.

3.11.2. Permittees shall providecontainment dikes or other structures tominimize effects of Oil spills at critical locationsalong the Pipeline in accordance withStipulation 2.14.

APPENDIX F

EXHIBIT E

COOPERATIVE AGREEMENTbetween

UNITED STATES DEPARTMENT OF THEINTERIOR

andSTATE OF ALASKA

regarding thePROPOSED TRANS-ALASKA PIPELINE

(Exhibit is proposed for deletion because construction of the Trans-Alaska pipeline is completed.Deletion is pending confirmatory discussions.)

APPENDIX F

APPENDIX F

E-1

EXHIBIT ECOOPERATIVE AGREEMENT

betweenUNITED STATES DEPARTMENT OF THE INTERIOR

andSTATE OF ALASKA

regarding thePROPOSED TRANS-ALASKA PIPELINE

THIS AGREEMENT, effective this 8th day ofJanuary, 1974, by and between the UnitedStates Department of the Interior (hereinafterreferred to as the "Department") and the State ofAlaska (hereinafter referred to as the "State"),which together are hereinafter referred to jointlyas "Parties,"

WITNESSETH

WHEREAS, the State has the authoritypursuant to AS 38.05.020 to enter into thisagreement with the Department in order toprotect the lands, waters and naturalenvironment of Alaska;

WHEREAS, the Secretary of the Interior(hereinafter referred to as the "Secretary") hasthe authority to enter into agreements involvingthe improvement, management, use andprotection of the public lands and their resourcespursuant to Section 102 of the Public LandAdministration Act, 74 Stat. 506 (1960), 43U.S.C. § 1363 (1970);

WHEREAS, the Parties have beenrequested to issue rights-of-way and otherauthorizations for the construction of an oilpipeline system from Prudhoe Bay to Valdez,Alaska;

WHEREAS, the Congress of the UnitedStates has determined that early construction ofsuch an oil pipeline system is in the nationalinterest and has authorized and directed theSecretary and other appropriate Federal officersand agencies to issue and take all necessary

action to administer and enforce rights-of-wayand other authorizations that are necessary foror related to the construction of the Trans-Alaskaoil pipeline system;

WHEREAS, the Legislature of Alaska, inspecial session, has enacted legislation toestablish authority and guidelines for a right-of-way lease for that system;

WHEREAS, the Secretary will designate aFederal Authorized Officer and the Governor ofAlaska will appoint a State Pipeline Coordinatorwho will, respectively, have general supervisionand control over the functions in Alaska of theDepartment and the State with respect to theconstruction of the pipeline system;

WHEREAS, it is anticipated that detailedtechnical and environmental stipulations relatingto construction of the pipeline system will beincorporated in the right-of-way and otherauthorizations of each of the Parties, and thatthe State and Federal stipulations will be similarin all major respects;

WHEREAS, it is necessary to provide forreview and approval of designs and surveillanceof construction activities in order to assurecompliance with the aforesaid stipulations; and

WHEREAS, it is the purpose of thisagreement to promote an effective workingrelationship between the Parties in order toprovide maximum protection for the environmentwithout unnecessary delays in construction ofthe pipeline system;

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NOW, THEREFORE, the Parties agree asfollows:

I. LANDS-LEASE AND PERMIT

1. The State and Department recognize thefollowing categories of land to be made subjectto the rights-of-way and other authorizations ofthe State or the Department and that such landsconstitute all of the land along the proposedpipeline right-of-way that is not owned by privateparties and therefore is subject to the authority ofeither the Department or the State to authorizerights-of-way.

(a) Lands patented to the State.

(b) Lands selected by and tentativelyapproved to the State and not withdrawnunder section 11(a)(2) of the AlaskaNative Claims Settlement Act, 85 Stat.696, 43 U.S.C. § 1610 (1970).

(c) Lands selected by the State and nottentatively approved and not withdrawnunder section 11(a)(2) of the AlaskaNative Claims Settlement Act.

(d) Lands selected by the State and nottentatively approved and which werewithdrawn under section 11(a)(2) of theAlaska Native Claims Settlement Act butwhich are not available for village orregional selection under section 22(l) ofthe Alaska Native Claims SettlementAct, 85 Stat. 713, 43 U.S.C. § 1621(1970).

(e) Lands selected by the State, bothtentatively approved and not tentativelyapproved, and withdrawn under sectionII(a)(2) of the Alaska Native ClaimsSettlement Act.

(f) Lands beneath navigable waters asdefined in Section 2 of the SubmergedLands Act, 67 Stat. 29, 43 U.S.C. § 1301(1970).

(g) Lands in Federal ownership that havenot been selected by the State.

2. The State will issue its right-of-way andother authorizations for lands in categories 1(a),1(b), and 1(f). The Department will issue its

rights-of-way and other authorizations for landsin categories 1(e) and 1(g).

3. Both the State right-of-way lease orother grant and the Federal right-of-wayauthorization will include the lands in categories1(c) and 1(d) and each will be effective inaccordance with the following terms:

(a) Lands in category 1(c) will be tentativelyapproved or patented to the State nolater than fifteen (15) days aftercompliance by the Parties with allapplicable regulations. The Parties willimmediately initiate and expeditiouslycomplete such compliance. The Statewill thereupon immediately proceed toissue a right-of-way lease or other grantand such authorizations as arenecessary for construction and operationof the pipeline system on said lands.

(b) The Department will take all necessaryaction preparatory to tentativelyapproving or patenting the lands incategory 1 (d) to the State within twenty-five (25) days from the effective date ofthis agreement and will tentativelyapprove or patent those lands promptlyupon receipt of notice from theCommissioner of Natural Resources thatthe State is prepared to issue a right-of-way lease or other grant and such otherauthorizations as are necessary forconstruction and operation of thepipeline system on said lands.

(c) The Federal right-of-way in and to landsin categories 1(c) or 1(d), or both, willvest in the Parties receiving it on thedate it is issued by the Department butonly upon the occurrence of one of thefollowing events, whichever occurs first:

(i) The Commissioner of NaturalResources notifies the Secretary inwriting that it is essential for theexpeditious construction of thepipeline system that the Federalright-of-way in and to some or all ofthe lands in categories 1(c) or 1(d),or both, vest in the Parties receivingit; or

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E-3

(ii) The lands in category 1(d) have notbeen tentatively approved to theState and a valid State right-of-waylease or other grant in and to thoselands has not been issued for theconstruction and operation of thepipeline system by March 10, 1974;or

(iii) The lands in category 1(c) have notbeen tentatively approved to theState and a valid State right-of-waylease or other grant in and to thoselands has not been issued for theconstruction and operation of thepipeline system by June 1, 1974;

Provided as conditions: First, that theFederal right-of-way is made subject to theState's valid pre-existing rights, if any, in and tothose lands; Second, that upon either validtentative approval or valid patent of any of thoselands to the State, the existence or subsequentissuance of a valid State right-of-way lease orother grant in and to those lands terminates theFederal right-of-way and other authorizations,and the State right-of-way lease or other grantthereupon applies in all respects to those lands;Third, that the parties who receive the Federalright-of-way and other authorizations agree inwriting to the first and second conditions hereinand that they will not challenge the validity of theState's right-of-way lease or other grant on thebasis of the existence of the Federal right-of-wayand other authorizations or their interest therein,and the Federal right-of-way recites these threeconditions; and, Fourth, that the Department willmake every reasonable effort to tentativelyapprove and patent the lands to the Stateexpeditiously.

II. SURVEILLANCE

1. While the Parties will establish andmaintain separate organizations to assurecompliance with the terms and stipulations oftheir respective right-of-way authorizations andwith their respective statutes and regulations,they will seek to coordinate the activities of theseorganizations as fully as possible. In theexecution of their respective responsibilities theParties will seek to provide maximum protectionfor the environment without unnecessary delays

in construction of the pipeline. Pursuant to thisgeneral agreement, it is further agreed that:

(a) The Parties will endeavor, both incentral offices and in the field, to locateall personnel in the surveillance effort,including agents and third partycontractors, in common locations and toutilize, insofar as possible, commonlogistical support, with the objective ofmaximizing communication between thetwo organizations.

(b) Except as prohibited by law or by theDepartment's pipeline right-of-wayagreement with the owners of the Trans-Alaska pipeline, (but the owners will berequired by the State right-of-way leaseto make the same available to theState), the Parties will share fully allinformation concerning the constructionof the pipeline system and thesurveillance thereof. The State and theFederal organizations will havecomplete and immediate access to theinformation of the other, on request, andthere will be regular exchange ofinformation regarding design reviews,application for and issuances of noticesto proceed, temporary suspensionorders, modification orders, reports oncompliance in the field, constructionchange recommendations, allsubmissions by the holders of the rights-of-way, all third party contractor reports,applications for and issuance ofpermission to resume activity, and allother similar information. The timing,location, method and type of informationexchanged shall be governed by theobjective of the fullest possible accessto information practical in order tomaximize the decision-making capabilityof the Parties.

(c) The Parties will have full and freeaccess to the lands of each other for allpurposes relating to the surveillance ofthe pipeline system and the enforcementof all State and Federal statutes andregulations.

2. All applications for notices to proceed,together with supporting documents, will be

APPENDIX F

E-4

reviewed by both the State Pipeline Coordinatorand the Federal Authorized Officer.

The State right-of-way lease will containprovisions regarding notices to proceed thatassure review by the Pipeline Coordinator withinthe same time period as provided in theDepartment's right-of-way authorizations. TheAuthorized Officer or his designee, on behalf ofthe Department, may issue notices to proceedinvolving construction of any portion of thepipeline system. The Pipeline Coordinator or hisdesignee, on behalf of the State, may issuenotices to proceed with respect to anyconstruction of the pipeline system on Statelands, and no notice to proceed on lands subjectto the State right-of-way lease will be effectiveunless signed by the State Pipeline Coordinator.

3. On lands subject to the Federal right-of-way authorizations, the Department willdetermine compliance with the terms andstipulations regulating the construction of thepipeline system. On lands subject to the Federalright-of-way authorization, where applicablestatutes and regulations of the State providingfor the protection of resources, the environment,or public health, safety or general welfare,impose additional requirements to, or morestringent standards than, those required by theFederal terms and stipulations for pipelineconstruction, operation or maintenance, theState law will control.

4. On lands subject to the State right-of-way lease, the determination of compliance withthose terms and stipulations regulating theconstruction of the pipeline system which do notdirectly affect the physical integrity of thepipeline, but which are necessary for theprotection of State lands and resources shall bemade exclusively by the State. On such landsthe State or the Department may issue anyorders necessary to assure compliance withthose terms and stipulations regulating theconstruction of the pipeline system that arenecessary to protect the physical integrity of thepipeline.

5. The Parties recognize that the uniquecharacteristics of the arctic and subarcticenvironment require special efforts to provide itwith optimum protection. The Parties will makeevery reasonable effort to ensure that

construction and operation methods andactivities will be planned and executed so as tominimize environmental degradation.

6. Fish and wildlife protection is regardedby the Parties as a special responsibility of thesurveillance effort which extends with commonconcern over the length of the pipeline. TheParties will encourage the formation, to theextent practicable, of a cooperative effort forsuch protection, sharing the fish and gamepersonnel and information resources of both theState and Federal Governments, and theapplication of this cooperative effort over bothState and Federal lands.

7. The Department shall have full and freeaccess at all times to the Valdez terminal site forthe purpose of enforcing the Department'sstipulations at that facility. The State will assuresuch access to the Department by makingappropriate provisions therefor in any lease orconveyance it may issue or grant with respect tothe lands embraced in the Valdez terminal site.

III. STATE HIGHWAY AND STATEAIRPORTS

1. The Department agrees to take suchaction pursuant to the Trans-Alaska PipelineAuthorization Act of November 16, 1973, P.L.93-153, as are necessary for the State toconstruct a public highway from the Yukon Riverto Prudhoe Bay. The State agrees to constructthe highway according to the Highway andAirport Stipulations attached hereto as Exhibit"A� and, if the State contracts to build thehighway, to include said stipulations as a part ofany agreement with its contractors.

2. The State has furnished the Departmenta map of the intended location of the highway,and upon completion of construction of thehighway will file with the Department a map ofdefinite location of the highway of similar scale.

3. The Department agrees to lease threesites for public airports pursuant to the Trans-Alaska Pipeline Authorization Act (supra). TheState agrees to build the airports according tothose provisions of the Highway and AirportStipulations that are pertinent to airportconstruction, and if the State contracts to build

APPENDIX F

E-5

the airports, to include said stipulations as a partof any agreement with such contractors.

4. The Department agrees to take allactions necessary to provide to the State, undernonexclusive permits, the free use of gravel orother materials necessary for construction of theState highway and the State airports pursuant tothe Trans-Alaska Pipeline Authorization Act(supra). All free use permits issued by theDepartment for such material sites shall includeprovisions of the Highway and AirportStipulations applicable to material sites.

5. The State shall have the right andresponsibility to enforce the applicableprovisions of the Highway and AirportStipulations referring to the construction of theState highway and State airports.

IV. MISCELLANEOUS

1. The Federal Authorized Officer and theState Pipeline Coordinator will developprocedures to implement the provisions of thisagreement.

2. In the implementation of this agreement,each Party will avoid unnecessary employmentof personnel and needless expenditure of funds.

3. This agreement shall remain in effectuntil construction of the Trans-Alaska pipeline iscompleted. However, in the event that eitherParty deems it necessary or desirable toterminate this agreement at an earlier time, itmay do so after giving the other Party sixty (60)days advance written notice thereof.

IN WITNESS WHEREOF, the Parties hereto have executed this agreement as of the date shownbelow:

STATE OF ALASKA United States of America/s/ William A. Egan Department of the Interior

Title: Governor /s/ Rogers C.B. MortonState of Alaska Title: Secretary of theJanuary 8, 1974 Interior

APPENDIX F

E-6

EXHIBIT A

Highway and Airport Stipulations

1. DEFINITIONS

1.1. "Highway" means the State highwayfrom the Yukon River to Prudhoe Bay, Alaska;and includes all permanent roads, bridges,tunnels, drainage structures, signs, guardrails,protective structures, and appurtenances relatedthereto or used in connection therewith.

1.2. "Airports" means the three publicairports for which the State of Alaska madeapplication on March 20,1970, under 49 U.S.C.§§ 211-214 (1970).

1.3. "State Pipeline Coordinator" meansthat individual designated by the State of Alaskawith authority over and responsibility for thesupervision of design review and construction ofthe Pipeline System or his designee.

1.4. "Federal Authorized Officer" meansthe Secretary of the Interior, or a persondelegated to exercise his authority with respectto the Pipeline System.

1.5. "Contractor" means the individual,corporation, or other entity, or the subcontractoror agent of such individual, corporation or otherentity, with which the State of Alaska contracts tobuild the Highway or Airports. In the event thatthe State undertakes to build the Highway orAirports itself, "Contractor" shall mean the Stateof Alaska.

1.6. "Notice to Proceed" means adocument signed by the State PipelineCoordinator authorizing some aspect of theconstruction of the Highway or Airports.

2. PROCEDURES

2.1. Regulation of Public Access

2.1.1. During construction of the Highway,the State shall provide alternative routes forexisting roads and trails across public lands.

2.1.2. The State shall make provisions forsuitable permanent crossings for the publicwhere the Highway right-of-way crosses existing

roads, foot trails, winter trails, or other rights-of-way.

2.2. Applicability of Stipulations

2.2.1. Nothing in these Stipulations shallbe construed as applying to activities of theState that have no relation to the Highway orAirports.

2.2.2. Nothing in these Stipulations shallbe construed to affect any right or cause ofaction that otherwise would be available to theState against any person other than the UnitedStates.

2.3. Responsibilities

2.3.1. With regard to the construction ofthe Highway and Airports: (1) The State shallensure full compliance with the terms andconditions of these Stipulations by its agents,employees and contractors (includingsubcontractors of any tier), and the employees ofeach of them. (2) Unless clearly inapplicable,the requirements and prohibitions imposed uponthe State by these Stipulations are also imposedupon the State's agents, employees, contractors,and subcontractors, and the employees of eachof them. (3 Failure or refusal of the State'sagents, employees, contractors, subcontractors,or their employees to comply with theseStipulations shall be deemed to be the failure orrefusal of the State. (4) The State shall requireits agents, contractors, and subcontractors toinclude these Stipulations in all contracts andsubcontracts which are entered into by any ofthem, together with a provision that the othercontracting party, together with its agents,employees, contractors, subcontractors, and theemployees of each of them, shall likewise bebound to comply with these Stipulations.

2.3.2. The State shall make separateapplication, under applicable statutes andregulations, for authorization to use or occupyFederal lands in connection with the Highway orAirports where the lands are not within theHighway right-of-way or Airport leases. This

APPENDIX F

E-7

shall include material sites, camp sites, wasteareas, storage areas, access roads, etc.

2.3.3. The Federal Authorized Officer mayrequire modification of the Highway or Airports,without liability or expense to the United States,as necessary to protect the integrity of theTrans-Alaska Pipeline.

2.4. Highway Design Approval

2.4.1. The State shall require detaileddesign submittals from Contractor for all riverand stream crossings.

2.4.2. All such submittals shall bereviewed by the State Pipeline Coordinator forconformity with the Stipulations set forth herein.

2.4.3. Upon approval of such design, aNotice to Proceed shall be executed andtransmitted to the Contractor. Such documentshall authorize the commencement ofconstruction on the element of the Highway forwhich design is approved.

2.5. Suspension of Construction

2.5.1. In the event the State PipelineCoordinator determines that the Contractor is inviolation of these Stipulations, he may ordersuspension of that portion of the work inviolation.

2.5.2. In the event that the FederalAuthorized Officer determines that theContractor is in violation of these Stipulations, hemay recommend that the State PipelineCoordinator order suspension of that portion ofthe work he deems to be in violation.

2.6 Changes in Conditions

Unforeseen conditions arising during designor construction of the Highway or Airports maymake it necessary to revise or amend theseStipulations to protect the environment and thepublic interest. In that event, the FederalAuthorized Officer and the State PipelineCoordinator, shall agree as to what revisions oramendments shall be made. If they are unableto agree, the Federal Authorized Officer shallhave final authority to determine the matter if theAirports are involved, and the State Pipeline

Coordinator shall have final authority todetermine the matter if the Highway is involved.

3. CONTRACTOR STIPULATIONS-GENERAL

3.1. Equal EmploymentOpportunity

By accepting this contract, Contractoragrees that, during the period of construction ofthe Highway and Airports, or for so long as thispermit shall be in effect, whichever is the longer,he shall comply with this Stipulation.

3.1.1. Contractor will not discriminateagainst any employee or applicant foremployment because of race, color, religion,sex, or national origin. Contractor will takeaffirmative action to ensure that applicants areemployed, and that employees are equallytreated during employment, without regard totheir race, color, religion, sex, or national origin.Such action shall include, but not be limited to,the following: employment, upgrading, demotion,or transfer; recruitment or recruitmentadvertising; layoff or termination; rates of pay orother forms of compensation; and selection fortraining, including apprenticeship. Contractoragrees to post in conspicuous places, availableto employees and applicants for employment,notices to be approved by the Authorized Officersetting forth the provision of this equalopportunity clause.

3.1.2. Contractor will, in all solicitations oradvertisements for employees placed by or onbehalf of Contractor, state that all qualifiedapplicants will receive consideration foremployment without regard to race, religion, sex,color or national origin.

3.1.3. Contractor will send to each laborunion or representative of workers with whichContractor has a collective bargainingagreement or other contract or understanding, anotice, to be provided by the Authorized Officer,advising the labor union or worker�srepresentatives of Contractor commitmentsunder this equal opportunity clause and shallpost copies of the notice in conspicuous placesavailable to employees and applicants foremployment.

APPENDIX F

E-8

3.1.4. Contractor will comply withExecutive Order No. 11246 of September 24,1965, as amended, and rules and regulationsand relevant orders of the Secretary of Labor.

3.1.5. Contractor will furnish allinformation and reports required by ExecutiveOrder No. 11246 of September 24, 1965, asamended, and by the rules, regulations, andorders of the Secretary of Labor, or pursuantthereto, and will permit access to Contractor'sbooks, records, and accounts by the StatePipeline Coordinator and the Federal AuthorizedOfficer and the Secretary of Labor for purposesof investigation to ascertain compliance withsuch rules, regulations, and orders.

3.1.6. In the event of Contractor'snoncompliance with this equal opportunityclause or with any of said rules, regulations, ororders, this contract may be cancelled,terminated or suspended in whole or in part andContractor may be declared ineligible for furthergovernment contracts or permits in accordancewith procedures authorized in Executive OrderNo. 11246 of September 24, 1965, as amended,and such other sanctions may be imposed andremedies invoked as provided in ExecutiveOrder No. 11246 of September 24, 1965, asamended, or by rule, regulation, or order of theSecretary of Labor, or as otherwise provided bylaw.

3.1.7. Contractor will include theprovisions of this equal opportunity clause inevery contract, subcontract or purchase orderunless exempted by rules, regulations, or ordersof the Secretary of Labor issued pursuant toSection 204 of Executive Order No. 11246 ofSeptember 24, 1965, as amended, so that suchprovisions will be binding upon each contractor,subcontractor or vendor. Contractor will takesuch action with respect to any contract,subcontract, or purchase order as the AuthorizedOfficer may direct as a means of enforcing suchprovisions including sanctions fornoncompliance; provided, however, that in theevent Contractor becomes involved in, or isthreatened with, litigation with a contractor,subcontractor or vendor as a result of suchdirection by the State Pipeline Coordinator,Contractor may request the United States toenter into such litigation to protect the interestsof the United States.

3.1.8. Contractor further agrees that it willbe bound by the above equal opportunity clausewith respect to its own employment practiceswhen it participates in federally assistedconstruction work.

3.1.9. Contractor agrees that it will assistand cooperate actively with the State PipelineCoordinator and the Federal Authorized Officerand the Secretary of Labor in obtaining thecompliance of Contractors and subcontractorswith the equal opportunity clause and the rules,regulations, and relevant orders of the Secretaryof Labor, that it will furnish the State PipelineCoordinator and the Federal Authorized Officerand the Secretary of Labor such information asthey may require for the supervision of suchcompliance, and that it will otherwise assist theState Pipeline Coordinator in securingcompliance.

3.1.10. Contractor further agrees that itwill refrain from entering into any contract orcontract modification subject to Executive OrderNo. 11246 of September 24, 1965, as amended,with a Contractor debarred from, or who has notdemonstrated eligibility for, Governmentcontracts and federally assisted constructioncontracts pursuant to the Executive Order andwill carry out such sanctions and penalties forviolation of the equal opportunity clause as maybe imposed upon Contractors andsubcontractors by the Federal Authorized Officeror the Secretary of Labor, pursuant to Part II,Subpart D, of the Executive Order. In addition,Contractor agrees that if it fails or refuses tocomply with these undertakings, the StatePipeline Coordinator may take any or all of thefollowing actions: Cancel, terminate, or suspendin whole or in part this contract; refrain fromextending any further assistance to Contractorunder the program with respect to which thefailure or refusal occurred until satisfactoryassurance of future compliance has beenreceived from the Contractor; and refer the caseto the Department of Justice for legalproceedings.

3.1.11. Certification ofNonsegregated Facilities

By accepting this contract, Contractorcertifies that Contractor does not and will notmaintain or provide for Contractor's employees

APPENDIX F

E-9

any segregated facilities at any of Contractor�sestablishments, and that Contractor does notand will not permit Contractor's employees toperform their services at any location, underContractor's control, where segregated facilitiesare maintained. Contractor agrees that a breachof this certification is a violation of the equalopportunity clause of this permit. As used in thiscertification, the term "segregated facilities"means, but is not limited to, any waiting rooms,work areas, restrooms and washrooms,restaurants and other eating areas, time clocks,locker rooms and other storage or dressingareas, parking lots, drinking fountains, recreationor entertainment areas, transportation, andhousing facilities provided for employees whichare segregated by explicit directive or are in factsegregated on the basis of race, color, religion,or national origin, because of habit, local customor otherwise. Contractor further agrees that(except where Contractor has obtained identicalcertifications from proposed Contractors andsubcontractors for specific time periods)Contractor will obtain identical certifications fromproposed Contractors and subcontractors priorto the award of contracts or subcontractsexceeding $10,000 which are not exempt fromthe provisions of the equal opportunity clause;the Contractor will retain such certifications inContractor's files; and the Contractor will forwardthe following notice to such proposedContractors and subcontractors (except wherethe proposed Contractors or subcontractorshave submitted identical certifications forspecific time periods): "NOTICE TOPROSPECTIVE CONTRACTORS ANDSUBCONTRACTORS OF REQUIREMENT FORCERTIFICATION OF NON-SEGREGATEDFACILITIES." A Certification of NonsegregatedFacilities, as required by the order (32 F.R.7439, May 19, 1967) on Elimination ofSegregated Facilities, by the Secretary of Labor,must be submitted prior to the award of acontract or subcontract exceeding $10,000which is not exempt from the provisions of theequal opportunity clause. The certification maybe submitted either for each contract andsubcontract or for all contracts and subcontractsduring a period (i.e., quarterly, semiannually, orannually).

3.2. Liabilities and Responsibilitiesof Contractor

Contractor shall abate any condition existingwith respect to the construction of the Highwayor Airports that causes or threatens to causeserious and irreparable harm or damage to anyperson, structure, property, land, fish and wildlifeand their habitats, or other resource. Any Stateor Federal property and fish and wildlife habitatharmed or damaged by the Contractor inconnection with the construction of the Highwayor Airports, regardless of fault, shall bereconstructed, repaired and rehabilitated by theContractor to the written satisfaction of the StatePipeline Coordinator. Contractor shall be liablein accordance with applicable laws for loss ordamage to property of others or for bodilyinjuries to or the death of any person arisingfrom or connected with the construction of theHighway or Airports.

3.3. Federal, State and Local Lawsand Regulations

Contractor shall comply with applicableFederal and State laws and all regulationsissued thereunder, existing or hereafter enactedor promulgated, affecting in any mannerconstruction of the Highway or Airports.

3.4. Antiquities and HistoricalSites

Contractor shall engage an archeologistapproved by the Federal Authorized Officer toprovide surveillance and inspection of theHighway and Airport sites for archeologicalvalues. If, in connection with any operationunder this contract, or any other contract enteredin connection with the Highway or Airports,Contractor encounters known or previouslyunknown paleontological, archeological, orhistorical sites, Contractor shall immediatelynotify the Federal Authorized Officer and theState Pipeline Coordinator and saidarcheologist. Contractor's archeologist shallinvestigate and provide an on-the-groundopinion regarding the protective measures to beundertaken by Contractor. The FederalAuthorized Officer may suspend that portion ofContractor's operations necessary to preserveevidence pending investigation of the site.

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Six (6) copies of all survey and excavationreports shall be filed with the Federal AuthorizedOfficer and the State Pipeline Coordinator.

3.5. Termination of Use

Upon termination of use of any part of theHighway or Airports, Contractor shall remove allimprovements and equipment, except asotherwise approved in writing by the StatePipeline Coordinator as to the Highway, and theFederal Authorized Officer as to the Airports,and shall restore the land to a condition that issatisfactory to them. The satisfaction of theState Pipeline Coordinator and FederalAuthorized Officer shall be stated in writing.

All Access Roads shall be "put-to-bed" byContractor upon completion of their use unlessotherwise directed by the Federal AuthorizedOfficer. "Put-to-bed" is used herein to mean thatsuch roads shall be left in such stabilizedcondition that erosion will be minimized throughthe use of adequately designed and constructedwaterbars, revegetation, and chemical surfacecontrol; that culverts and bridges shall beremoved by Contractor in a manner satisfactoryto the Federal Authorized Officer; and that suchroads shall be closed to use. Contractor'srehabilitation plan shall be approved in writing bythe State Pipeline Coordinator and the FederalAuthorized Officer prior to termination of use ofany such road or any part thereof.

3.6. Public Improvements

Contractor shall protect existingimprovements on Federal and State lands duringconstruction of the Highway or Airports. Exceptas authorized for temporary purposes by theState Pipeline Coordinator and FederalAuthorized Officer, the Contractor shall notobstruct any road or trail with logs, slash, ordebris.

3.7. Camping, Hunting, Fishing,and Trapping

Contractor shall satisfy the State PipelineCoordinator that it has and will adequatelyinform its employees, agents, contractors,subcontractors, and their employees, ofapplicable laws and regulations relating tohunting, fishing, and trapping.

3.8. Small Craft Passage

The creation of any permanent obstruction tothe navigation of small craft in streams isprohibited.

3.9. Survey Monuments

Contractor shall mark and protect allgeodetic survey monuments encountered duringthe construction of the Highway or Airports.These monuments are not to be disturbed;however, if such a disturbance occurs, theFederal Authorized Officer shall be immediatelynotified thereof in writing.

If any land survey monuments, corners, oraccessories (excluding geodetic surveymonuments) are destroyed, obliterated ordamaged, Contractor shall employ a qualifiedland surveyor to reestablish or restore same inaccordance with the "Manual of Instructions forthe Survey of Public Lands" and shall recordsuch survey in the appropriate records.Additional requirements for the protection ofmonuments, corners, and bearing trees may beprescribed by the Federal Authorized Officer.

3.10. Fire Prevention andSuppression

Contractor shall promptly notify the StatePipeline Coordinator and the Federal AuthorizedOfficer and take all measures necessary andappropriate for the prevention and suppressionof fires in accordance with 43 CFR 2801.1-5 (d).Contractor shall comply with their instructionsand directions concerning the use, preventionand suppression of fires. Use of open fires inconnection with construction of the Highway orAirports is prohibited unless authorized in writingby the State Pipeline Coordinator as to theHighway or the Federal Authorized Officer as tothe Airports.

3.11. Health and Safety

Contractor shall take all measuresnecessary to protect the health and safety of allpersons affected by its activities performed inconnection with the construction of the Highwayor Airports and shall immediately abate anyhealth or safety hazards. Contractor shallimmediately notify the State Pipeline Coordinator

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of all serious accidents which occur inconnection with such activities.

4. CONTRACTOR STIPULATIONS-ENVIRONMENTAL

4.1. Environmental Briefing

Prior to and during construction of theHighway and Airports, Contractor shall providefor environmental and other pertinent briefings ofconstruction and other personnel by suchFederal and State employees as may bedesignated by the Federal Authorized Officerand the State Pipeline Coordinator. Contractorshall arrange the time, place and attendance forsuch briefings upon their request.

4.2. Pollution Control

4.2.1. General

Contractor shall conduct all activitiesassociated with the Highway and Airports in amanner that will avoid or minimize degradationof air, land and water quality. In the constructionof the Highway and Airports, Contractor shallperform its activities in accordance withapplicable air and water quality standards andrelated plans of implementation, includingemission standards, adopted pursuant to theClean Air Act, as amended (42 U.S.C., sec.1857, et seq.), and the Federal Water PollutionControl Act, as amended (33 U.S.C., sec. 1160).

4.2.2. Water and Land Pollution

4.2.2.1. Contractor shall comply withapplicable "Water Quality Standards" of theState of Alaska as approved by theEnvironmental Protection Agency.

4.2.2.2. Mobile ground equipment shallnot be operated in lakes, streams, or riversunless such operation is approved in writing bythe State Pipeline Coordinator.

4.2.3. Air Pollution and Ice Fog

4.2.3.1. Contractor shall utilize andoperate all facilities and devices used inconnection with the construction of the Highwayand Airports in such a way so as to avoid orminimize air pollution and ice fog.

4.2.3.2. Emissions from equipment,installations, and burning materials shall meetapplicable Federal and State air qualitystandards.

4.2.4. Pesticides, Herbicides, andother Chemicals

Contractor shall use only non-persistent andimmobile types of pesticides, herbicides andother chemicals. Each chemical to be used andits application constraint shall be approved inwriting by the State Pipeline Coordinator prior touse.

4.2.5. Sanitation and WasteDisposal

4.2.5.1. "Waste" means all discardedmatter, including but not limited to human waste,trash, garbage, refuse, oil drums, petroleumproducts, ashes and equipment.

4.2.5.2. All waste generated inconstruction of the Highway and Airports shall beremoved or otherwise disposed of in a manneracceptable to the State Pipeline Coordinator. Allapplicable standards and guidelines of theAlaska State Department of EnvironmentalConservation, the United States Public HealthService, the Environmental Protection Agency,and other Federal and State agencies shall beadhered to by Contractor. All incinerators shallmeet the requirements of applicable Federal andState laws and regulations and shall be usedwith maximum precautions to prevent forest andtundra fires. After incineration, material notconsumed in the incinerator shall be disposed ofin a manner approved in writing by the StatePipeline Coordinator. Portable or permanentwaste disposal systems to be used shall beapproved in writing by the State PipelineCoordinator.

4.3. Buffer Strips

4.3.1. Public Interest Areas

No construction activity in connection withthe Highway or Airports shall be conductedwithin one-half (1/2) mile of any officiallydesignated Federal, State or municipal park,wildlife refuge, research natural area, recreationarea, recreation site, or any registered National

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Historic Site or National Landmark, unless suchactivity is approved in writing by the FederalAuthorized Officer as to Federal areas or theState Pipeline Coordinator as to State areas.

4.3.2. Streams

The Highway clearing limits shall be limitedso as to provide three hundred (300) footminimum buffer strips of undisturbed land alongstreams unless otherwise approved under 2.4herein.

4.4. Erosion Control

4.4.1. Contractor shall conduct allHighway and Airport construction activities so asto avoid or minimize disturbance to vegetation.

4.4.2. The design of the Highway andAirports shall provide for the construction oferosion control facilities that will avoid orminimize erosion.

4.4.3. The erosion control facilities shallbe constructed to avoid erosion and to lessenthe possibility of forming new drainage channelsresulting from Highway or Airport constructionactivities. The facilities shall be designed andconstructed in such a way as to avoid orminimize disturbance to the thermal regime.

4.4.4. Stabilization

4.4.4.1. Surface materials taken fromdisturbed areas shall be stockpiled and utilizedduring restoration unless otherwise approved inwriting by the State Pipeline Coordinator as tothe Highway and by the Federal AuthorizedOfficer as to the Airports. Stabilization practices,as determined by the needs for specific sites,shall include but shall not be limited to seeding,planting, mulching, and the placement of matbinders, soil binders, rock or gravel blankets, orstructures.

4.4.4.2. All disturbed areas shall be left ina stabilized condition satisfactory to the StatePipeline Coordinator as to the Highway and theFederal Authorized Officer as to the Airports.Such satisfaction shall be stated in writing.

4.4.5. Crossings of Streams,Rivers or Flood Plains

4.4.5.1. Contractor shall prevent orminimize erosion at streams and river crossingsand those parts of the Highway or Airports withinflood plains.

4.4.5.2. Temporary access over streambanks shall be made through use of fill rampsrather than by cutting through stream banks,unless otherwise approved in writing by theState Pipeline Coordinator.

4.4.5.3. Timing and methods of crossingsshall be subject to control and alteration by theState Pipeline Coordinator to protect fishpassage and spawning and aquatic resourcesgenerally.

4.4.6. Seeding and Planting

Seeding and planting of disturbed areasshall be conducted as soon as practicable and, ifnecessary, shall be repeated until vegetation issuccessful, unless otherwise approved in writingby the State Pipeline Coordinator. All otherrestoration shall be completed as soon aspossible.

4.4.7. Excavated Material

Excavated material not utilized for Highwayor Airport construction shall be disposed of in amanner approved in writing by the FederalAuthorized Officer, if wasted outside of thefacility right-of -way.

4.5. Fish and Wildlife Protection

4.5.1. Passage of Fish

4.5.1.1. Contractor shall provide foruninterrupted movement and safe passage offish. Any artificial structure or any streamchannel change that would cause a blockage offish shall be provided with a fish passagestructure or facility that meets all Federal andState requirements. The proposed design shallbe submitted to the State Pipeline Coordinator inaccordance with Stipulation 2.4.1.

4.5.1.2. Pump intakes shall be screenedto prevent harm to fish.

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4.5.1.3. Abandoned water diversionstructures shall be removed or filled to preventtrapping or stranding of fish.

4.5.1.4. If material sites are approvedadjacent to or in certain lakes, rivers, or streams,the State Pipeline Coordinator, either on his owninitiative or at the request of the FederalAuthorized Officer, may require the Contractor toconstruct levees, berms, or other suitable meansto protect fish and fish passage and to preventsiltation of streams or lakes.

4.5.2. Fish Spawning Beds

4.5.2.1. "Fish Spawning Beds" means theareas where anadromous and resident fishdeposit their eggs.

4.5.2.2. Contractor shall avoid channelchanges in Fish Spawning Beds designated bythe State Pipeline Coordinator; however, wherechannel changes cannot be avoided in suchbeds, new channels shall be constructedaccording to written standards supplied by theState Pipeline Coordinator.

4.5.2.3. Fish Spawning Beds shall beprotected from sediment where soil material isexpected to be suspended in water as a result ofconstruction activities. Settling basins shall beconstructed to intercept silt before it reachesstreams or lakes.

Contractor shall comply with any specialrequirements made by the State PipelineCoordinator for a stream system in order toprotect Fish Spawning Beds. Contractor shallrepair all damage to Fish Spawning Bedscaused by construction of the Highway orAirports.

4.5.3. Zones of RestrictedActivities

Contractor's activities in connection with theconstruction of the Highway or Airports in keyfish and wildlife areas may be restricted by theState Pipeline Coordinator during periods of fishand wildlife breeding, nesting, spawning,lambing or calving activity and during majormigrations of fish and wildlife. The StatePipeline Coordinator shall provide Contractorwritten notice of such restrictive action. From

time to time, the State Pipeline Coordinator shallfurnish Contractor a list of areas where suchactions may be required, together withanticipated dates of restriction.

4.6. Material Sites

4.6.1. Acquisition of Materials

4.6.1.1. If Contractor requires materialsfrom the public lands, Contractor shall requestthe State of Alaska to make application, inaccordance with 43 CFR, Part 3621, "Free Useof Mineral Materials." Contractor shall submit amining plan in accordance with 43 CFR, Part 23.No materials may be removed by Contractorwithout the written approval of the FederalAuthorized Officer.

4.6.1.2. Insofar as possible, use ofexisting material sites will be authorized inpreference to new sites.

4.6.2. Layout of Material Sites

Material site boundaries should be shaped insuch a manner as to blend with surroundingnatural land patterns. Regardless of the layoutof material sites, primary emphasis shall beplaced on prevention of soil erosion and damageto vegetation.

4.7. Clearing

4.7.1. Boundaries

Contractor shall identify approved clearingboundaries on the ground prior to beginningclearing operations. All timber and othervegetative material outside clearing boundariesand all blazed, painted or posted trees which areon or mark clearing boundaries are reservedfrom cutting and removal with the exception ofdanger trees or snags designated as such by theState Pipeline Coordinator.

4.7.2. Timber

4.7.2.1. Prior to initiating clearingoperations, Contractor shall notify the FederalAuthorized Officer of the amount ofmerchantable timber, if any, which will be cut,removed, or destroyed in the construction of theHighway or Airports, and shall request that theState make separate application for the free use

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of such timber in accordance with 43 CFR,Part 5510.

4.7.2.2. All trees, snags, or other woodymaterial cut in connection with clearingoperations shall be cut so the resulting stumpsshall not be higher than six (6) inches measuredfrom the ground on the uphill side.

4.7.2.3. All trees, snags, and other woodymaterial cut in connection with clearingoperations shall be felled into the area within theclearing boundaries and away from watercourses.

4.7.2.4. Hand clearing shall be used inareas where the State Pipeline Coordinator as tothe Highway and the Federal Authorized Officeras to the Airports, determine that use of heavyequipment would be detrimental to existingconditions.

4.7.2.5. All debris resulting from clearingoperations and construction that may blockstream flow, delay fish passage, contribute toflood damage, or result in stream bed scour orerosion shall be removed.

4.7.2.6. Logs shall not be skidded oryarded across any stream without the writtenapproval of the State Pipeline Contractor.

4.7.2.7. No log landing shall be locatedwithin three hundred (300) feet of any watercourse, except where impractical, then only withthe written approval of the State PipelineCoordinator.

4.7.2.8. All slash shall be disposed ofwithin the Highway right-of-way or Airport leaseunless otherwise directed in writing by theFederal Authorized Officer as to the Airports orthe State Pipeline Coordinator as to theHighway.

4.8. Disturbance of Natural Waters

All activities of Contractor in connection withthe construction of the Highway or Airports thatmay create new lakes, drain existing lakes,significantly divert natural drainages,permanently alter stream hydraulics, or disturb

significant areas of stream beds are prohibitedunless such activities along with necessarymitigation measures are approved in writing bythe Federal Authorized Officer as to the Airportsand the State Pipeline Coordinator as to theHighway.

4.9. Off Right-of-Way Traffic

Contractor shall not operate mobile groundequipment off the Highway or Airportconstructions limits or authorized areas unlessapproved in writing by the Federal AuthorizedOfficer as to the Airports and the State PipelineCoordinator as to the Highway, or whennecessary to prevent harm to any person.

4.10. Aesthetics

The Federal Authorized Officer or StatePipeline Coordinator may impose suchrequirements as he deems necessary to protectaesthetic values.

4.11. Restoration

4.11.1. Areas disturbed by Contractorshall be restored by Contractor to thesatisfaction of the State Pipeline Coordinator asto the Highway, and the Federal AuthorizedOfficer as to the Airports as stated in writing.

4.11.2. All cut and fill slopes shall be leftin a stable condition.

4.11.3. Materials from the Highway andAirports, haul ramps, berms, dikes, and otherearthen structures shall be disposed of asdirected by the State Pipeline Coordinator as tothe Highway and the Federal Authorized Officeras to the Airport.

4.11.4. Vegetation, overburden, and othermaterials removed during clearing operationsshall be disposed of by Contractor in a mannerapproved in writing by the State PipelineCoordinator as to the Highway and the FederalAuthorized Officer as to the Airports.

4.11.5. Upon completion of restoration,Contractor immediately shall remove allequipment and supplies from the site.

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5. CONTRACTOR STIPULATIONS -TECHNICAL

The following requirements shall becomplied with in design and construction ofHighways and Airports.

5.1. Special Standards

5.1.1. All pre-construction, construction,and post-construction operations shall beconducted to minimize permafrost degradationand damage to the environment, and to providemaximum protection to wildlife and humanbeings.

5.1.2. Temporary bridges shall be locatedso as to reserve the superior site and alignmentfor future permanent bridges.

5.1.3. Embankment sections shall beused in preference to excavated sectionswherever practicable and, in general, theHighway shall follow terrain features.

5.1.4. Unless otherwise approved by theState Pipeline Coordinator, organic materialresulting from clearing operations shall not beincorporated in the road prism, but may be usedas a mat overlay below the road prism.

5.2. Permanent Culverts andBridges

Culverts and bridges shall be designed toaccommodate a 50-year flood in accordancewith criteria established by the AmericanAssociation of State Highway Officials and theFederal Highway Administration.

5.3. Erosion

5.3.1. Erosion control procedures shallaccommodate and be based on the runoffproduced by storm and snow melt conditions

having a 50-year occurrence interval. Theprocedure shall also accommodate effects thatresult from thawing produced by flowing orponded water on permafrost terrain.

5.3.2. Slopes of cuts through streambanks shall be designed and constructed tominimize erosion and prevent slides.

5.3.3. Where necessary because of outfallerosion, stilling basins shall be constructed atthe outflow end of culverts. To prevent erosionthe pool sides shall be established byappropriate methods; E.g., by the use of riprap.

5.4. Slope Stability

Areas subject to mudflows, landslides,mudslides, avalanches, rock falls, and othertypes of mass movements shall be avoidedwhere practicable in locating the Highway andAirports. Where such avoidance is not practical,the Highway or Airport design, based upondetailed field investigations and analysis, shallprovide measures to prevent the occurrence of,or protect the Highway or Airports against theeffects of mass movements.

5.5. Construction Operations

5.1.1. All pre-construction andconstruction activities shall be conducted so asto avoid or minimize thermal and otherenvironmental changes and to provide maximumprotection to fish and wildlife and their habitat,and people. All surface modifications shall beplanned and executed in such a way that anyresulting degradation of permafrost will notjeopardize adjoining structure foundations.

5.5.2. Acceptable plans, procedures andquality controls that ensure compliance withthese Stipulations shall be submitted inaccordance with Stipulation 2.4.1.

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